身份筹划的避税效应：增值税纳税人身份选择与税负变动

Abstract

As a foundational system of tax administration in China, the VAT taxpayer identity conversion system serves a threefold function: it enhances the efficiency of tax collection and management, upholds tax equity across enterprises, and safeguards the stable growth of VAT revenue. The system designates taxable sales volume as the primary criterion by which enterprise types are classified. Yet, by adopting a rigid, "one-size-fits-all" framework, the system inadvertently creates scope for strategic behaviour. In particular, small-scale enterprises situated near the policy threshold are motivated to select an optimal taxpayer identity according to their own development needs. This strategic selection produces an anomalous distribution of enterprises on either side of the threshold – a distribution shaped by subjective decision-making rather than by market fundamentals – which may, in turn, distort the actual VAT burden borne by the two categories of enterprise. This paper employs the bunching method to empirically investigate the impact of VAT taxpayer identity selection behaviour on the actual VAT burden of enterprises, and further examines the causes and mechanisms by which small-scale taxpayers "refuse to grow up". The results indicate that the actual VAT burden of small-scale taxpayers that engage in identity planning is relatively low compared to that of small-scale taxpayers that convert into general taxpayers. Further analyses reveal that, in order to preserve their current tax identity, small-scale taxpayers adjust their taxable sales. This adjustment manifests in three concurrent patterns under the VAT taxpayer identity conversion system: the average sales price of products sold by small-scale taxpayers declines significantly, sales volume drops markedly, and the level of book–tax difference rises. In essence, taxpayers reduce sales prices, lower sales volumes, or engage in financial manipulation to ensure that their taxable sales satisfy the identification criteria for small-scale taxpayers. The findings of this study carry clear policy implications. First, the supervision of tax policy implementation should be strengthened – for instance, by establishing a closed-loop management mechanism for taxpayer identity that extends from government to enterprises, and by ensuring that the tax system remains aligned with corporate development needs so as to facilitate its effective implementation. Second, a supply–demand platform for small-scale and general enterprises should be actively developed, employing two-way tax incentives to unblock the input tax deduction chains and transaction channels for enterprises undergoing identity conversion. Third, tax collection and administration measures for small-scale enterprises ought to be refined, and the regulatory barriers that separate enterprises of different taxpayer identities should be dismantled. Finally, the tax environment of small-scale enterprises must be strictly regulated. To this end, the verification and cross-checking of corporate accounting information should be strengthened, and a dynamic tracking and management mechanism for enterprise tax data should be established, whereby enhanced information supervision compels enterprises, in turn, to raise the quality of their tax data.