遗产税制度比较研究

遗产税自古埃及起征至今历时千年,其存在必要性毋庸置疑。不同的遗产税制度或以效率为导向,或以公平为导向,或兼顾两者,有各自的优点和不足。境外遗产税制度对中国的启示在于:价值导向决定制度差异;核心内容不可或缺;税收减免要借鉴各国长处并考虑本国实际;应切实减轻遗产税负并严厉惩戒逃避遗产税的行为。如何防止遗产税形式化、如何实现遗产税的本土化、如何防范税法道德化等,都是亟待解决的焦点问题。

Comparative study on institution of inheritance tax

Inheritance tax has been putting into effect since ancient Egyptian times for thousand years, which leaves no necessity to doubt its existence. Different inheritance taxations have different orientations. They focus on either the productivity or fairness, or both. Different inheritance taxations have their respective advantages and disadvantages. The enlightenments to China of foreign inheritance taxations are as follows:the value orientation decides the differences between institutions; the core content is indispensable; the tax relief needs to learn from foreign good practices and consider domestic context; and the tax burden should be reduced and the activity of tax evasion should be severely punished. To prevent the inheritance tax to become a mere formality, to achieve the localization of inheritance tax, and to prevent the moralization of tax law etc. are the key issues to be solved urgently.