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学界相关研究中常常将近代英、美两国的治税思想都笼而统之于“no taxation without representa-tion”这一英文句式表述之下,由于缺乏对其具体语境的进一步分辨,从而造成了对两国近代治税思想“同意同源”的混淆性认识。“no taxation without representation”在近代英国与美国的治税思想中并不具有统一一致的意涵而是各自代表着不同的思想表达,其分别体现为“无代表不得征税”与“无代表,不纳税”。在此基础上进一步阐明了两者虽在历史上就征税权的控制方面都曾起到过积极、进步作用,但是又都具有着各自深刻的历史局限性,而这种局限性恰是我们当下欲引鉴西方治税经验来构建自己的税制安排时所不应却也最易被忽略的。
Related studies in academia often cite the idea of tax administration in modern Britain and the United States both in the English sentence format of “no taxation without representa- tion ” and because of the lack of further understanding of its specific context So as to create a confusing understanding of the idea of taxing the two countries in their modern era and agreeing on the same origin. “no taxation without representation ” in modern Britain and the United States do not have the same meaning of tax governance idea but each represents a different expression of ideas, which are manifested as “no representative shall not tax ” and “No representative, no tax ”. On this basis, we further clarify that although both have played a positive and progressive role in the historical control of the taxation right, they both have their own profound historical limitations, and this limitation is exactly what we The current attempt to learn from Western tax experience to build their own tax arrangements should not be the most easily overlooked.