超越国家汲取能力: 国际数字税实践的政治经济分析

Beyond the State 's Resource Extracting Capacity A Political and Economic Analysis of Digital Tax Practices

摘要:

税收是现代国家汲取能力的集中体现, 既反映了国家对经济社会活动的干预, 更是现代国家实现有效治理的资源保障。 进入数字时代, 经济社会的数字化转型赋予了税收新的政治经济意义, 数字税成为全球税制转型的重要议题。 国家间差异化数字税征收实践主要源于全球数字经济产业链中的角色差异, 而非国家间汲取能力的强弱。 对于积极推进数字税实践的市场国而言, 其征税逻辑则因资源汲取能力的差异而有所不同, 这源于数字化转型带来的结构关系变革, 给汲取能力迥异的国家带来了不同挑战。 总之, 现代国家将数字税视为应对其在国内和全球两个治理体系中权威流失的一种解决方案, 数字时代的税收实践在一定程度上具备了超越资源汲取的政治经济意涵。

Abstract:

Taxation serves as the principal avenue through which the state extracts revenue, while also standing as a pivotal nexus in the interaction between the state and society. It reflects the state?s intervention in economic and societal activities, functioning as an assurance for the attainment of efficient governance within the modern state. Therefore, taxation is regarded as an indicator of a modern state?s capability to extract resources. The digitization of both the economy and society has bestowed new political and economic significance upon taxation. As a result the concept of digital taxation has risen to prominence as an important topic within the broader transformation of the global tax system. The growing digitization of economic activities brings about a separation between the location where multinational enterprises are registered and where they truly conduct their economic operations. This separation renders the traditional international tax system incapable of adapting to the emerging global profit-sharing mechanism. In response to the challenge, the Organization for Economic Cooperation and Development （OECD） has put forth the concept of _“significant economic presence_” as the primary criterion for assessing the tax liability of multinational corporations in host countries. This approach recognizes that physical presence is no longer a prerequisite for the substantial involvement of multinational digital enterprises in the economic activities in host countries. Subsequently， several European countries initiated the imposition of a digital services tax, which levies a direct tax on the profit income generated from the digital economy activities of multinational enterprises. This article points out that differences in digital tax practices among countries reflect their respective roles in the global digital economy industry chain , rather than resource extraction capability. To be concrete , being market country within the digital economy chain is a necessary condition for the imposition of digital taxes, and digital tax practices are no longer predicated on revenue extraction capacity. Meanwhile , as active promoters of digital tax practices , market countries may differ in their taxing logics due to variations in resource extraction capacity , which stems from the fact that the structural changes brought about by the digitalization present distinct challenges for countries with varying levels of resource extraction capacity. In market countries characterized by limited extraction capacities , where the state has long had a low level of dependence on society , digital transformation reinforces the reverse domination of state authority by social forces , driving the state to respond to the governance challenges posed by the erosion of government authority through taxing the digital economy. In market countries with strong extraction capacities , on the other hand , the digital transformation of their economies may lead to the loss of their dominant position in the traditional industrial chain as well as the loss of discursive and decision-making leadership in global digital governance. This could result in digital taxes becoming a means of seeking strategic autonomy and balancing interests in new structural relationships. To sum up , modern states see digital taxes as a means to address the loss of their authority in both domestic and global governance systems. The digital tax practice carries political economy connotations that extend beyond resource extraction. In the case of China , as an increasing number of local digital enterprises enter overseas markets , a comprehensive understanding of its role as a producer in the global digital economy industry chain becomes crucial. This understanding will enable China to effectively manage the spillover effects brought about by the digital tax policies of various countries.