我国会计准则与企业所得税法差异研究

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论文中文摘要:会计与税收相互独立,又密切联系。税收缴纳的多少,是以企业的生产经营情况为基础,而企业生产经营情况又是通过财务数据体现出来。财务数据的真实、可靠,是税收征管的基础和前提,但由于会计与税法分别遵循不同的原则,服务不同的对象,追求不同的目标,两者之间又存在必然的差异。《中华人民共和国企业所得税法》第二十一条规定:“在计算应纳税所得额时,企业财务、会计处理办法与税收法律、行政法规的规定不一致的,应当依照税收法律、行政法规的规定计算。”这就是所得税的计税依据是应纳税所得额而不是会计利润的根本原因。近年来,随着经济市场化和国际化的日益加强,我国加快了会计制度和税收制度改革的步伐。2006年2月,财政部颁布了1项基本准则和38项具体会计准则,标志着我国建立了与国际趋同的会计准则体系;2007年3月,第十届全国人民代表大会通过了《中华人民共和国企业所得税法》,统一了内外资企业所得税。新准则与新税法颁布实施后,两者之间的差异呈现出新的变化,而分析会计准则与企业所得税法之间的这些差异并按照各自要求进行财税处理,才能达到提高会计信息质量和依法履行纳税义务的目的。本文通过规范研究和统计分析相结合的方法,从宏观和微观两个层面对会计准则与企业所得税法的差异进行研究,力求能够比较全面地归纳并总结这一问题,在内容上做到理论与实际的结合,既能解释差异产生的理论根源,深入分析差异背后反映的会计准则与企业所得税法在原则和观念上的区别,又能说明实际操作中对差异有哪些相应的纳税调整事项。在差异的解决方面,笔者认为由于会计准则和企业所得税法规范的对象和目标不同,两者的差异无法消除。如果以税法为依据进行会计核算,会导致会计信息失真,如果以会计核算的收入和利润作为计税依据将会弱化税收职能,因此以法德为代表的“会税”统一模式是行不通的。从企业所得税纳税申报表的四次演变(1994年版-1998年版-2006年版-2008年版)来看,此表由过去的以利润表为基础,逐步改变为以税法口径的“收入总额”减“扣除项目”格式设计,显示出税法与会计制度的独立性。而从我国会计准则的演变来看,我国会计准则的改革与建设是以国际会计准则和美国会计准则为蓝本。因此,应保持会计准则和企业所得税法的相互独立性,但不应全盘接受美英为代表的“会税”分离模式,会计准则和企业所得税法应相互协调,并与经济环境相融合。协调二者之间的差异是促进会计准则和企业所得税法两者自身的完善,完善会计准则和企业所得税法又是协调差异的前提和必然要求。笔者现在西藏自治区国家税务局工作,作为一名从事税收工作的税收管理员,在日常的税收检查和税收管理工作中,、对于因会计与税法的差异所造成过多的纳税人财务核算成本、纳税遵从成本和税务机关的管理成本,有着切身体会。在撰写本文的过程中,笔者利用近四个月的时间回到单位上班,亲身参与了对西藏自治区国税局所辖近十户企业的税收检查。通过税收检查、与纳税人的亲身交流以及与同事们的热情讨论,对因会计与税收种种不同所造成的差异有了更为深刻、、理性的认识,也为本文的写作取得了征管一线的“第一手”素材。但是,由于西藏本身相比内地各省经济总量的落后,加之西藏本土大型企业较少,造成其“会税”差异的处理及纳税调整方法较为简单,可供借鉴分析的案例较少,尤其缺乏对上市公司、关联交易等较为复杂的案例。本人以此文作为自己的毕业论文,也是想结合自身的工作,通过对二者的差异进行详细的分析研究,期望能对自己以后的工作有所帮助。全文共分五个部分。第一、介绍会计准则与企业所得税法之间的关系,主要阐述会计与税收的关系,即在与会计相关的诸多经济范畴中,当属税收与会计的关系最为密切。会计立足于微观层次而又影响到宏观领域,而税收立足于宏观层次而作用于微观领域,会计直接面向企业但也与整个社会经济运行相连,而税收首先基于国家宏观经济调控的需要而对具体的企业实施征收管理。会计为税收提供信息支持,而且这种支持延伸为二者相互的支持,可以简单地理解为:税收征纳要利用会计核算所提供的资料,而处理结果又反馈给会计进而影响会计利润等数据信息。但从总体上看,二者又在按照各自的方向独立发展,会计与税收不同的职能和学科属性决定了会计与税收在其制度设计过程中遵循不同目标、处理原则以及业务规范。结合诺布斯(Nobes)分类法,概述会计准则与企业所得税法关系模式并提出自己对我国“会税”关系模式选择的意见,即我国“会税”模式的现实选择应为“适度”分离。第二、从克拉尼斯基定律着手对会计准则与企业所得税法的差异进行了理论分析。通过比较会计目标与税收立法宗旨、会计信息质量要求与税收立法原则,找出会计准则与企业所得税法产生差异的根源。笔者认为会计准则与企业所得税法的规范目标不同,决定了其基本前提和遵循的原则存在一定差别,这是会计准则与企业所得税法产生差异的根源。最后通过博弈论的知识,分析二者利益博弈的关系,指出在现代企业治理结构下,从政策制定到作用于企业过程中至少存在两次利益博弈,即会计准则与税法制定部门的利益博弈和企业与政府的利益博弈,在每次利益博弈过程中都会导致企业所得税法与会计准则的分离。第三、本部分为本文研究的重点。利润总额与应纳税所得额之间的差异是会计准则与企业所得税法差异的最终体现,而各种繁多的纳税调整项目则是利润总额与应纳税所得额之间差异的具体体现。在具体分析会计准则与企业所得税法的差异时,为了增强文章的实用性和时效性,笔者以《中华人民共和国企业所得税年度纳税申报表》(2008版)中的附表三“纳税调整项目明细表”为主线,以会计准则和企业所得税法为研究对象,分类为收入类差异、扣除类差异、资产类差异、准备金调整项目等四个大的项目进行详细分析,尽可能做到全面细致地分析二者的差异。第四、选择2006-2008年沪市602家上市公司作为研究样本,对我国上市公司的会计利润与应纳税所得额差异进行描述性统计,指出随着会计准则和企业所得税法的实施,其差异的扩大已是不争的事实。第五、通过以上的研究和分析,提出了自己对会计准则与企业所得税法差异协调的原则和建议。笔者认为在差异协调的原则方面,应坚持其统一性与独立性的原则,即对于企业财务、会计处理办法有规定,而税收法律、行政法规没有规定的,总体处理原则是按照已有的财务会计规定处理。这样既有利于缩小和协调税法与会计的差异,也有利于减轻纳税人财务核算成本、纳税遵从成本和降低税务机关的管理成本;只有会计处理和税务处理保持各自的独立性,才能保证会计信息的真实性和应纳税额的准确性。针对二者差异,笔者建议:1、建立为税收征管服务的会计观,优化与税收征管相关的会计准则的设计;2、在税制建设中地借鉴会计准则的合理内核,提高税制的科学性与合理性。本文的创新之处体现在两个方面:第一、对会计准则与企业所得税法的差异,进行了全面、系统的研究分析,始终坚持从宏观和微观两个角度研究问题。宏观即二者的理论差异,尤其是会计目标与税收立法宗旨的差异、会计信息质量要求与税收立法原则的差异;微观即二者的实务差异,即在收入类、扣除类、资产类、准备金等方面的具体差异,并提出在实际操作中对差异的纳税调整方法。第二、笔者在分析会计准则与企业所得税法的具体差异时,以《中华人民共和国企业所得税年度纳税申报表》(2008版)中的附表三“纳税调整项目明细表”为主线,以会计准则和《企业所得税法》为研究对象,进行详细分析,增强了文章的实用性和时效性,在内容上做到了理论与实际相结合
Abstract(英文摘要): Accounting and taxation independent of each other, but also close contact. The amount of tax paid is based on the production operation is the basis of enterprise production and management situation is reflected through the financial data. Financial data, real, reliable, and is the basis and prerequisite for tax collection, but because each follow different accounting and tax principles, services, different objects, the pursuit of different objectives, between which there are inevitable differences. "The People’s Republic of China Enterprise Income Tax Law," Article XXI provides that:"in the calculation of the amount of taxable income, corporate finance, accounting treatment and tax laws and administrative regulations are inconsistent and should be in accordance with tax laws and administrative regulations calculation. "This is the income tax is based on taxable income rather than the root causes of the accounting profit.In recent years, with the market economy and the increasing internationalization of China to speed up the accounting system and tax system reform. In February 2006, the Ministry of Finance issued a basic norms and 38 specific accounting standards, indicates that China has established a system of international convergence of accounting standards; in March 2007, of the Tenth National People’s Congress adopted the "People’s Republic of the Enterprise Income Tax Law ", the unification of domestic and foreign income taxes. The new norms and new tax law enacted after the implementation of the difference between the two presents new changes, while the analysis of accounting standards and corporate income tax law and in accordance with these differences between the requirements of their tax treatment can be achieved to improve the quality of accounting information and in accordance with law to fulfill the purpose of tax liability.In this paper, standardize research and statistical analysis of a combination of methods, from the macro and micro levels of accounting standards and the "Enterprise Income Tax Law" to study the differences, and strive to be able to compare comprehensively summarized and concluded the problem, the contents do The combination of theory and practice, the theory could explain the differences arising from the root causes behind the reflected in-depth analysis of differences in accounting standards and the "Enterprise Income Tax Law" in the principles and conceptual differences, but also shows the actual operation of the difference between what the appropriate tax adjusting events. In the resolution of differences, the author believes that because of accounting standards and the "Enterprise Income Tax Law" normative targets and goals are different, the difference can not be eliminated. If the tax laws as a basis for accounting, will lead to distortion of accounting information, if accounting income and profits tax as a tax based on the functions to be weakened, and therefore, represented by France and Germany "would tax" unified model is not feasible. From corporate income tax returns of the four Evolution (1994 edition-2006 Edition-1998 Edition-2008 edition of years), it seems, this table from the past to the income statement based on the gradual change to tax law, caliber of "total income" minus " deduction "format designed to show independence of the tax and accounting system. From the evolution of China’s accounting standards, our country’s reform and construction of accounting standards based on International Accounting Standards and U.S. accounting standards modeled. Therefore, accounting standards should be maintained and the "Enterprise Income Tax Law" of mutual independence, but not fully acceptable to the United States and Britain as the representative "would tax" separation mode, accounting standards and the "Enterprise Income Tax Law" should be coordinated with each other and with the economic environment fusion. Coordination of the differences between the two is to promote the accounting standards and the "Enterprise Income Tax Law," both self-perfection, improve accounting standards and the "Enterprise Income Tax Law" is the premise and the inevitable differences in the coordination of requirements.The author is now the Tibet Autonomous Region State Administration of Taxation as part of the one engaged in tax work, tax administrators, in the daily management of the tax inspection and tax work, accounting and tax law for the result caused by differences in financial accounting cost taxpayers too much, tax compliance costs and the cost of administering the tax authorities, has personal experience. In the course of writing this article, the author used the past four months to return to the flat to go to work, personally participated in the Tibet Autonomous Region, nearly 10 enterprises under the jurisdiction of the IRS tax examination. Through the tax inspection, and the taxpayer’s personal exchanges as well as the enthusia with colleagues discuss different kinds of accounting and tax revenue caused by the difference has become more profound and rational knowledge, but also the writing of this paper has made collection and management front-line "First first-hand "material. However, due to Tibet itself, the overall economy compared to backward provinces in the Mainland, coupled with the Tibetan local large-scale enterprises with less, resulting in its "will tax" differences in treatment and a relatively simple tax adjustment methods ailable to draw on the analysis of fewer cases, in particular, the lack of For listed companies, related party transactions and other more complicated case. I to this, article as his thesis, but also want to combine their work, through both a detailed analysis of differences, look forward to their future endeors.Full-text is divided into five parts.First, the introduction of accounting standards and the "Enterprise Income Tax Law," the relationship between the principal explained the relationship between accounting and taxation, that is associated with the accounting of many sectors of the economy, the course ought to tax and accounting most closely. Accounting is based on the micro-level, but for the macro-areas, while the tax is based on the macro level and acting on the microscopic fields, accounting directly for the enterprise but also connected with the whole socio-economic operations, and taxation the first country-based macroeconomic regulation and control needs of the collection and management of specific enterprises. Accounting for tax to provide information support and this support extends to both mutual support, can be simply understood as:to take advantage of tax levied for the information provided by accounting and processing results and then fed back to the accounting impact of the accounting profits data information. However, generally speaking, both also in accordance with the direction of their independent development, accounting and tax the different functions and disciplines properties determine the accounting and taxation systems in their design process, follow different objectives, management principles and business standards. With Nobbs (Nobes) classification, an overview of accounting standards and the "Enterprise Income Tax Law" relationship model and make their own income and tax income of China’s views, of the relationship between mode selection, which is our duty models will be a realistic choice should be "appropriate" separation..Second, from the start of the accounting standards Clara Nissky Law and the "Enterprise Income Tax Law" differences in the theoretical analysis. By comparing the fiscal objectives and purposes of tax legislation, accounting information quality requirements and the principles of tax legislation, accounting and tax laws to find out the root causes of the differences arise, I believe that accounting standards and the "Enterprise Income Tax Law" goals are different from the norm, decided to follow its basic premise and There is a certain difference in principle, it is accounting standards and the "Enterprise Income Tax Law" the root causes of the differences. Knowledge of the final adoption of game theory to analyze the relationship between the two interests of the game, pointing out that in the modern corporate governance structure, from policy formulation to act on the business process in the interests of at least twice a game, that is, accounting standards and tax laws and the development of sectoral interests of game Game of the interests of business and government, in the interests of the game each time the process will lead to the separation of tax law and accounting standards.Third, the Department is divided into the focus of this study. The total profit and taxable income is the difference between the accounting standards and the "Enterprise Income Tax Law," the ultimate expression of differences, while the wide array of tax adjustments is the total profit and taxable income differences between the concrete embodiment. In a concrete analysis of accounting standards and the "Enterprise Income Tax Law," the differences, in order to enhance the relevance and timeliness of the article, the author of "The People’s Republic of China enterprise income tax returns the year" (2008 version) of Schedule III "Tax Adjustment Project List "main line, to accounting standards and the" Enterprise Income Tax Law "as the object of study, classified as class differences in income, net of class differences, differences in asset classes, reserve adjustments and other four large projects for detailed analysis, as far as possible be detailed and thorough analysis of the differences between the two. Fourth, select the 2006-2008 Shanghai-602 listed companies as a research sample of listed companies on China’s accounting profit and taxable income differences in descriptive statistics, pointing out that with the accounting standards and the "Enterprise Income Tax Law," the implementation of the expansion of their differences is an indisputable fact.Fifth, the above research and analysis, put forward its own accounting standards and the "Enterprise Income Tax Law" differences in the coordination of principles and recommendations. I believe that the differences in the principles of co-ordination should stick to its principles of unity and independence, that is for the corporate finance, accounting treatment is provided for.under the tax laws and administrative regulations do not provide, and the general management principles in accordance with existing financial accounting regulations. This helps to reduce and coordination of tax and accounting differences, but also help reduce the cost of taxpayers, financial accounting, tax compliance costs and reduce the cost of administering the tax authorities; only the accounting treatment and tax treatment to maintain their independence in order to ensure that accounting information authenticity and accuracy of tax liability. For the difference between the two, I propose:1, the establishment of accounting for tax collection services, the concept of optimization and tax collection and accounting standards related to the design; 2, in the tax system in greater draw on the rational core of accounting standards, improve the tax system scientific and reasonable.Innovations of this article is reflected in two aspects:First, accounting standards and the "Enterprise Income Tax Law," the difference between a comprehensive, systematic research and analysis, always adhere to the macro and micro two angles. That both differences in macroeconomic theory, in particular the legislative intent of accounting objectives and tax differences, accounting information quality requirements and differences in the principles of tax legislation; micro-namely, the substantive differences between the two, namely, income class, excluding class, asset class, reserve, etc. are specific differences, and to propose differences in the actual operation of the tax adjustment method.Secondly, the author in the analysis of accounting standards and the "Enterprise Income Tax Law" specific differences in the interest of "The People’s Republic of China Enterprise Income Tax Annual tax returns" (2008 version) of Schedule 3 "schedule of tax adjustments," the main line, with accounting standards and the "Enterprise Income Tax Law" as the object of study, carried out a detailed analysis of the articles to enhance the relevance and timeliness of the contents to achieve a combination of theory and practice.
论文关键词: 会计准则;税法;差异;协调;
Key words(英文摘要): Accounting;Tax;Difference;Coordination;