个税递延型商业养老保险的国外经验及我国借鉴探究

个税递延型商业养老保险作为第三支柱商业养老保险的一种主要形式，发端于欧美国家，主要有以美国为代表的投资型模式和以德国为代表的保险型模式。基于对国外模式、经验的考察以及对国内实行个税递延型商业养老保险的理论基础、必要性和可行性等分析，得出在我国采用个税递延型商业养老保险的路径选择：加大制度创新与供给，建立个税递延型商业养老保险；制度规范与税收优惠政策并举；营造良好的社会氛围，增强民众保险与责任共担意识；统筹精准管理与精算平衡。

Foreign Experience of Tax-deferred Private Pension Insurance and the Implications to China

As one of the main forms of the three pension insurances,tax-deferred private pension insur-ance was originated in Europe and America,mainly represented by American investment model and German insurance model.A number of measures in tax-deferred private pension insurance are pro-posed based on the review of foreign models and experience and the analyses of the necessity,feasibili-ty and theoretical foundations for domestic implementation of tax-deferred private pension insurance. First,institutional innovation and supply should be increased for the establishment of tax-deferred private pension insurance business;second,the standardization of the institution should be comple-mented by the tax preferential policies;third,a good social atmosphere should be created to enhance the awareness of public insurance and sharing responsibility;fourth,the overall precision manage-ment and the actuarial balance should be integrated.