税收筹划文献综述

Topic：Tax Regulation Effect and Train of Thought in Real Estate Market——An Analysis Based on Tax Shifting and the Reasonable Distribution of Tax BurdenThe author：G. Zuckerman; C. Rendall;H. HergethAbstract：Tax is to adjust the real estate market is one of the most effective economic levers, current macro-control almost all came from circulation step of lead to the actual effect of policy implementation is poor. And from the current real estate market of tax distribution and tax burden Angle can be found in the current analysis of real estate tax regulation practice, the only fully consider the whole real estate market tax allocation and the reality of the real estate market tax burden, we can find out the correct policy regulation organizations. The current real estate market tax regulation the key policy should be levied for the vacancy of real estate heavier retain link of taxation, and to the people of real estate is living consumption should implement a proper duty reduction or exemption.Keywords：Real estate tax, tax burden, the tax burden distribution, property taxesThe article briefly generalize the meanings,characteristics and principias about the ratepaying design.At one time,as the example of the real estate industry,the text taking practical designing cases have laboured real estate companies how to deal with ratepaying design,which is considered one of the important approaches to logically debase their costs and improve their competition abilities.Along with the growing popularity of Chinese real estate, Chinese government is adjusting its laws and regulations on foreign-investor’ investment in Chinese real estate companies. Currently, foreign investor has to undergone complex procedures to directly establish a real estate company in China and it is hard to be approved. As a result, many foreign investors join Chinese real estate by purchasing domestic real estate companies. Compared with purchasing land in China and then establishing a real estate company, the way of purchasing Chinese real estate company and is favorable for lower tax, simpler procedure and easier to be approved, but the disadvantage is the uncertainty in the asset of company planned to purchase and the debt risk. Though the company performing no business activities has lower risks in its asset and debt, those risks could be diminished by due diligence, issuing notice of company’s debt, requiring statement and promise of the company purchased. In terms of this, purchasing Chinese real estate company through a series of legal arrangement is a practical and easily operated approach to join Chinese real estate.Land for housing is scarce. Few people’s speculation and extravagant demand for housing seriously damage the most people’s basic need for shelter. The house property tax shou ld be set up to embody social equity, to restrain the speculation and luxurious demand for housing, and protect and encourage people’s reasonable housing demand.Local authorities should decide an exemptible living space per capita, in reference to current local average living space per capita. The area in addition to the exemptible living space per capita, should be taxed by progressive rate, the larger the additional area is, the higher the rate should be. That’s really fair.The current living space per capita plus 50 percent more as reasonable improvement demand, could be considered reasonable and be exempt from the house property tax. For example, if the current living space per capita is 40, the exemptible living space per capita could be 60.The standard by local average living space per capita is more accurate and reasonable than that by housing suite per family. It could eliminate the tax elusion by way of false divorce. It could also limit the luxurious need for too large houses.The tax should be measured by the property’s concluding price when the transaction is actually concluded. That is simple and efficient, and has few disputes. If the tax is measured according to the changing current price, the initial valuation and yearly update of the valuation would be very difficult, disputable, and would probably cause corruption and make the operation of the tax much less feasible.If the forthcoming house property tax has exemptible living space per capita, if the lowest rate, a little lower so as not to cause the low or middle income owners to lose their only one or two houses or become poor because of the tax, then the tax could come into effect more smoothly.Too light a house property tax could not control the house price. Too heavy a house property tax could harm the whole economy, and even endanger the social stability. So the house property tax is not the best measure to control the real estate market. Yet, the tax could embody the social equity and add to the government revenue.篇名：房地产市场税收调控效应及其调整思路——基于税负转嫁与税负合理分配的分析作者：G. Zuckerman; C. Rendall;H. Hergeth摘要：税收是调节房地产市场最有效的经济杠杆之一,现行的调控政策几乎都是从流转环节入手,导致政策实施的实际效果较差.而从现行房地产市场的税负分配和税负转嫁的角度进行分析可发现在现行房地产税收调控实践中,只有充分考虑整个房地产市场税负分配及现实中房地产市场的税负转嫁,才能找到政策调控的正确着力点.现行房地产市场税收调控政策的重点应是对空置的房地产征收较重的保有环节的税收,对百姓消费居住的房地产则应实施合理的减免税.关键词：房地产税制,税负转嫁,税负分配,物业税纳税筹划是近年来在我国发展迅速、方兴未艾的一个新兴领域,所谓“纳税筹划”,是指纳税人在不违反现行法律规定的前提下,通过对其应税行为的事前、事中进行合理筹措和安排,尽可能减少纳税的行为或者推迟纳税时间而取得税后利益最大化的经济行为。

税收学毕业论文文献综述在现代社会中，税收作为一种财政手段和国家治理的重要工具，对于国家经济的发展和社会稳定起着至关重要的作用。

税收学作为研究税收的学科，涵盖了税收的原理、政策、制度、管理等多个方面。

本文旨在通过对税收学领域的相关文献进行综述，探讨税收学研究的现状和发展趋势，以及其中的重要理论框架和方法。

一、税收学的研究领域及发展历程税收学作为一门学科，其研究领域涉及广泛，包括税收的目标与功能、税收原理和理论、税收政策与制度、税收管理与征收等方面。

税收学的发展历程可以追溯到古代，但现代税收学的形成主要集中在19世纪后半叶。

随着经济全球化的加剧和国际税收竞争的日益激烈，税收学的研究逐渐趋向国际化。

二、税收学的重要理论框架1.税收目标与功能理论税收目标与功能是税收学研究的重要方向之一。

相关理论主要探讨税收的宏观与微观目标，如促进经济发展、调节收入分配、实现社会公平与公正等功能。

2.税收原理与理论税收原理与理论主要包括公平原则、效率原则和可行性原则等。

公平原则涉及纳税人的权益保护和税收的合理分配；效率原则关注如何最大化税收对经济的促进作用；可行性原则则强调税收政策的可操作性与可持续性。

3.税收政策与制度税收政策与制度研究主要涉及税种选择、税率设计、税收优惠、税收避税与逃税等。

相关理论分析税收政策对经济和社会的影响，并提出相应的政策建议。

4.税收管理与征收税收管理与征收研究关注税收的执行与管理机制，包括税收征管体制、纳税人合规行为、税务稽查等方面。

理论研究旨在提高税收征收效率和减少违法行为。

三、税收学研究的方法与技术税收学研究常常运用多种方法与技术，以深入分析税收政策与实践的问题。

其中，文献研究、实证研究、比较研究、案例研究等方法被广泛应用于税收学领域。

四、税收学研究的现状与趋势目前，随着全球经济一体化程度的加深和国际税收规则的变化，税收学研究呈现出以下几个趋势：1.国际化和跨学科研究的趋势：国际税收竞争、跨国税收规则以及全球治理等问题引发了税收学研究国际化和跨学科研究的趋势。

企业所得税税收筹划是企业在合法合规的前提下，通过合理运用税法规定的优惠政策和税收政策，降低纳税额，提高企业经济效益的一种税务管理方式。

税收筹划是合法的，是企业应尽的义务，但必须在法律规定的范围内进行。

在进行税收筹划时，企业要遵循稳妥和适度的原则，不能违法规定和损害国家的税收利益。

下面将通过对一些企业所得税税收筹划案例参考文献的分析，来帮助读者更深入地了解企业所得税税收筹划的具体操作方法和效果。

1. 郭达《企业所得税筹划的理论与实务》郭达的这本专著详细地介绍了企业所得税税收筹划的理论基础和实际操作方法。

书中对企业所得税的基本概念、税收筹划的原则和方法、税收筹划与企业经营决策的关系等内容进行了全面深入地阐述，为企业的税收筹划工作提供了理论指导和实务操作的参考。

2. 王军《企业所得税法律实务及筹划》这是一本介绍企业所得税法律实务和筹划案例分析的专业书籍。

王军在书中系统地介绍了企业所得税的税率、纳税对象、纳税基础等基本概念，同时通过一些实际的税收筹划案例进行了分析与讨论，为企业在实际操作中遇到的税收筹划问题提供了可行的解决思路和方法。

3. 胡光《企业所得税筹划案例与分析》通过对一些企业所得税筹划案例的详细分析，胡光在这本专著中总结了一些成功的税收筹划经验和方法。

书中提到了企业在资产转让、股权转让、跨境投资等方面的税收筹划案例，分析了这些案例中成功的筹划方法和不利的因素，为企业在相似情况下的税收筹划提供了有益的借鉴。

4. 张三《企业所得税优惠政策的筹划应用》这本书主要介绍了各类企业所得税优惠政策的具体应用和操作方法。

张三结合了多年的税务实务经验，通过具体的案例分析和操作步骤，详细地阐述了如何合理利用国家税收优惠政策，降低企业所得税负担，增加企业的经济效益。

通过对以上四本专著的分析可以看出，企业所得税税收筹划在实际操作中需要遵循税法的规定，同时要结合企业自身的经营情况和国家税收政策进行合理筹划。

税收筹划要因地制宜，没有统一的模式，必须根据企业的实际情况和国家政策的变化来灵活运用。

完善税收政策重要性的文献综述范文一、引言。

税收，这个看似有些枯燥但却与我们生活息息相关的东西，就像一个无处不在的精灵，在经济社会这个大舞台上扮演着举足轻重的角色。

税收政策要是完善了，那可就像是给经济的快车装上了超级引擎，还能给社会公平这块大蛋糕切得更加均匀合理呢。

所以，咱们来好好聊聊关于完善税收政策重要性的那些事儿，看看各路大神在文献里都是咋说的。

二、对经济发展的重要性。

1. 资源配置优化。

很多文献都指出，完善的税收政策就像是一个超级指挥家，能够巧妙地引导资源的流向。

比如说，通过税收优惠政策，就可以鼓励企业投资那些新兴的、有潜力但风险较高的产业，像现在热门的可再生能源领域。

企业一看，搞太阳能、风能这些项目，能少交点税呢，那还不赶紧的。

这样一来，资源就从那些传统的、可能已经有点饱和的产业，慢慢流向了新兴产业，整个社会的资源配置就更加合理、高效了。

就好比是给资源这个大部队重新排兵布阵，让每个士兵（资源）都能在最需要的战场上（产业）发挥最大的作用。

2. 促进经济增长。

从宏观经济增长的角度来看，税收政策的完善也是一把“金钥匙”。

合理的税收水平能够给企业创造一个良好的发展环境。

要是税收太高了，企业就像是背着重重的壳的蜗牛，走得特别艰难，哪里还有心思去扩大生产、创新产品呢？相反，要是税收政策能恰到好处，企业就有更多的资金可以用来投资新技术、招聘新员工，这就像给企业打了一针强心剂，整个经济也就跟着蓬勃发展起来了。

就像种庄稼一样，税收政策就是土壤的肥力，肥力合适，庄稼（企业）就能茁壮成长，最后迎来大丰收（经济增长）。

3. 稳定经济波动。

税收政策在经济波动的时候还能充当“稳定器”的角色。

在经济过热的时候，政府可以适当增加税收，把市场上过多的钱收回来一些，就像给经济这匹跑得有点疯的马勒紧缰绳。

而在经济不景气的时候呢，减少税收，让企业和老百姓手里能多留点钱，刺激消费和投资，这就好比给经济这个有点病恹恹的病人喂点补药。

纳税筹划文献综述及外文文献资料本文档包括改专题的：外文文献、文献综述一、外文文献文献信息标题：Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in Ghana 作者：Kawor, Seyram; Kportorgbi, Holy Kwabla期刊：International Journal of Economics and Finance第6卷，第3期，页码：162-168，2014年Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in GhanaKawor, Seyram; Kportorgbi, Holy KwablaAbstractThe study sought to ascertain the level of tax planning of firms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies listed on the Ghana Stock Exchange over a twelve year period from 2000. The longitudinal correlative designed was used. The results indicate that that firms' tendency to engage in intensive tax planning activities reduces when tax authorities maintain low corporate income tax rates. Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. It is concluded that investors must institute systems to ensure tax planning benefits reflect significantly in their pockets.Keywords: Ghana stock exchange, tax planning, market performance, longitudinal correlative design, investors1. IntroductionOver the years and throughout the world, the history of taxation brings out one fact; that taxes are coercive in nature and therefore economic units which are assigned the tax liability never wholly intend to bear the actual tax burden (Commonwealth Association of Tax Administrators (CATA), 2007). Economic units, more specifically, corporate bodies are always adopting ways to minimise, postpone, or avoid entirely, the payment of tax. The attempts by the economic units to reduce, postpone or avoid tax payment can be legal or illegal. The legal means is called tax planning while the illegal means is called tax evasion. The dire consequence of tax evasion makes it an unattractive option for listed companies (Murphy, 2004).The practice of tax planning dates back to 1947 when learned judge Hand, in the case Commissioner v Newman, held that there is nothing sinister in arranging ones affairs so as to keep taxes as low as possible. Hoffman's (1961) tax planning theory supports this argument. According to Hoffman, it is a necessity for firms to understand the prevailing tax laws and apply the laws in a manner that ensures the firms minimise their tax exposure. Hoffman posits that it makes no economic sense to pay more tax than what the law demands. Scholes and Wolfson's (1992) tax planning framework also underscores the need for corporate bodies to engage in tax planning. According to Scholes and Wolfson, a successful company is the one that is properly attuned to its tax environment.International governmental organizations, such as CA TA (2009), suggest that corporate bodies in Ghana, especially the large entities, engage in complex tax planning activities. Research by civil society groups such as Christian Aid (2008), Action Aid (2011), and Dan Watch (2011), confirm this assertions made bythe Domestic Revenue Division. The missing element in the findings is thequantitative expression of the tax planning activities of the firms.The traditional thinking is that firms that derive maximum benefit from tax planning perform better than those that do not plan their taxes (Murphy, 2007). From the empirical perspective, tax planning is positively associated with firms' performance. For instance, Desai and Hines (2002); Chen, Chen, Chen and Shelvin (2010) reported positive association between tax planning savings and firm performance. The argument is that tax represents cost of doing business, and any action that has the potential of minimising tax cost reflects in higher firm performance. This argument presupposes that tax planning cost and risk does not exceed the savings from the planning.Few studies in the UK dispel the traditional relationship between tax planning and firm performance. While admitting that tax planning has a positive association with accounting performance, Desai and Dharmaphala (2007) reported that tax planning has a neutral association with market performance. Indeed Abdul-Wahab (2010) found a negative association between tax planning and firm performance. Kportorgbi (2013) suggested that corporate governance strength plays a mediating factor in the tax planning-firm performance relationship.A study of the effect of tax planning savings on firms' market performance is crucial for all stakeholders in the emerging security markets such as the Ghana stock Exchange. In fact each possible relationship has a unique implication for the players. For instance, a positive association implies that tax planning produces a win-win situation for both management andshareholders (investors). A negative association connotes that tax planning benefits may not eventually trickle to the pocket of the shareholder. Indeed, a negative association may be an indicative of the existence of agency problem, where management is inclined to pursue tax planning to enhance their own lot rather than advancing the interest of the investor. Where a neutral association is established, it will invoke a follow up study on the possible factors that could influence the relationship either positively or negatively. Secondly, the study is necessary to inform tax planning agents and investors on the dynamics of tax planning1.1 Objective of the StudyThe primary objective of this study is to explore the relationship between tax planning savings of firms listed on the Ghana Stock Exchange and firm market performance. The study also seeks to examine the simultaneous influence of other firm specific variables on the tax planning-market performance relationship.1.2 Tax Planning Intensity of Firms in GhanaCommentators on tax behaviour of firms in Ghana paint a picture that suggests that large firms engage in tax planning activities. For instance CATA (2009) posits that Ghana Revenue Authority lost seventy-four million pounds between 2005 and 2007 to the European Union (EU) in tax revenue as a result of tax avoidance by several multinational companies. Murphy (2004) also reported that firms have complex gamut of arsenals to reduce their tax burden. The reports indicate that the tax avoiding mechanism of firms are largely allowed by the tax laws. There are also indications that the firms take advantage of the loopholes in the tax laws to derive unintended tax benefits. Theavenues for tax planning usually revolve around locational reliefs, industry-specific concessions and capital allowance provitions. Others are time variables and entity variables.Most of the reports are not precise in their estimation of the benefits that firms achieve through tax planning. The lack of precision in measuring tax planning intensity is largely attributed to the insufficient reporting of issues of taxation by firms. Aside the mandatory disclosures to tax authorities, firms are reluctant in disclosing much on tax behaviours. This is due to the perceived thin line that exist between tax planning and tax evasion. Listed companies, however, provide provide adequate information necessary to estimate the tax savings of the firms. This is made possible by virtue of the financial reporting guidelines provided by the security exchange commision.2. Review of Related LiteratureThis section is subdivided into theoretical review and empirical review. The theoritical review encapsultes the Hoffman's (1961) tax planning theory. Three main empirical studies are reviewed. They are Desai and Hines (2002), Desai and Dharmaphala (2009) and Abdul-Wahab (2010).2.1 Hoffman's Tax Planning TheoryAccording to Hoffman (1961) tax planning seeks to divert cash, which would ordinarily flow to tax authorities, to the corporate entities. Tax planning activities are desirable to the extent that they reduce taxable income to the barest minimum, without sacrificing accounting income. The theory is premised on the fact that firms tax liability is based on taxable income rather than accounting income. The idea is thus to intensify activities that reduce taxable income but has no indirect relationship on accounting profit. The theory thus recognised a positiveassociation between firm tax planning activity and firm performance.Hoffman (1961) also recognised the role of tax cost in the tax planning activities. The theory thus provided that the positive association between tax planning and corporate performance is on a basic assumption that tax benefits from the tax planning exceed tax cost. The scope of the Hoffman's tax planning theory does not address the dynamics of tax planning and market performance. As capital markets develop and the separation of ownership and control of corporate bodies become well-spread, the need for a comprehensive tax planning theory is imperative. This need is rather addressed through the empirical perspective than through theoretical perspective (Inger, 2012).2.2 Empirical Review and Development of HypothesisDesai and Hines (2002) provide evidence on firm performance and tax planning behaviour of firms. Again, the study investigates the relationship between tightening of tax systems and market value of firms. The study was based on 850 listed US firms. The study sample was purposively selected to reflect the characteristics desired by the researchers. The study was cross sectional and the data relates to year 2000. Correlative-description design was adopted. Simple regression and t-tests were used to establish the relationships. Desai and Hines established that intensive tax planning is associated with higher firm performance. On the other hand, the study reported that tightening of the tax system is positively associated with higher market performance of firms. The findings of Desai and Hines (2002) are similar to that reported by Chen, Chen and Chen (2010). Desai and Dharmapala (2007) provided a comprehensive study that incorporates tax planning, corporate governance andfirm performance. The study used 4,492 observations on 862 firms over the period 1993 to 2001. This panel data was drawn from the Compustat and Execucomp databases, merged with data on institutional ownership of firms from the CDA/Spectrum database. Firms' performance is measured using Tobin's q and governance quality is proxied by the level of institutional ownership. Tax planning is measured by inferring the difference between the income reported to capital markets and tax authorities (the book-tax-gap). Two analysis models were adopted-the OLS model and the IV estimation model. The OLS results shows that the average effect of tax planning on corporate performance is not significantly different from zero. In other words, there is no relationship between tax planning and firm performance. The study howeverreports a positive association between tax planning savings and performance for well-governed firms. Desai and Dharmapala (2007) thus concluded that corporate governance mediates the tax planning-firm performance relationship. The IV estimate shows a higher effect of corporate governance on firm performance.Abdul-Wahab (2010) provides a result that differs from the findings of Desai and Hines (2002), Desai and Dhamarpala (2009), and Chen, Chen, Chen and Shelvin. Abdul-Wahab's (2010) study sought to establish a relationship between tax planning savings of firms and their value. The study simultaneously investigates the moderating influence of corporate governance. Abdul-Wahab's study employed 240 firms listed on the London stock exchange from 2005 to 2007. Tax planning was proxied by the difference between the effective tax rate of the entities and the applicable statutory tax rates. Self-constructed governance indexwas constructed using corporate governance mechanisms. Firms' value was represented by the Tobin's Q. The data was analysed using panel regression analysis model. As a check, the OLS model was also used.The results indicate a negative relationship between firm value and tax planning activities. Abdul-Wahab (2010) explains the relationship with reference to tax planning cost and risk. The study suggested that tax planning cost and risks associated with tax planning have the potential of derailing the benefits that should have accrued to shareholders. The researcher maintains that as tax planning activities increase, the tax costs and risks outweighs the benefits.Due to the diversity of the relationships found between tax planning and firms' market performance, it is right to develop a null hypothesis as:H1: There is an association between tax planning and firms' market performance.It is unreasonable to suggest that tax planning is the only determinants of firm performance. Baring the existence of multicollinearity between (among) the explanatory variables, sales growth, financial leverage, firm size and age of the firms will be introduced into the regression models. Several studies, including Desai and Hines (2002), Desai and Dharmaphala (2007), Abdul-Wahab (2010) reported positive association between firm performance and sales growth, firm size and financial leverage. It is thus clear to develop the null hypothesis that:H2: Firm performance and sales growth and firm size are positively associated.Firms' age, according to Desai and Dharmapala (2007) and Abdul-Wahab (2010) has a negative association with marketperformance of firms. This gives rise to the third null hypothesis that:H3: Firms age and financial leverage are negatively associated with firms' market performance. 3. Methodology Longitudinal correlative design is adopted for the study. Longitudinal design is essential if the same research entities sampled in a cross section are then re-sampled at different times (Creswell, 2009; De Vaus, 2001). According to the authors, the design helps overcome limitations associated with the "snap shot" approach of cross sectional designs.The study population comprises all non-financial firms listed on the Ghana stock exchange. As of June 2013, twenty-three (23) out of thirty-five (35) firms listed on the Ghana Stock Exchange were non-financial companies. Financial companies are excluded from the population. Previous researchers posit that the financial sector is a highly regulated sector and as such regulations blur the relationship that exist among the variables to be studied (O'Hamon & Taylor, 2007; Desai & Dharmapala, 2009; Abdul-Wahab, 2010).The study uses a panel data for twelve-year period, from 2000 to 2011. Data for the study is collected from the database of the Ghana Stock Exchange. Panel regression model is adopted fordata analysis and the Ordinary least square (OLS) been the method of regression.The regression model is summarized as:(1)α = (alpha) shows the constant affecting net profit margin on corporate tax.Tobin's q (market performance) = (market capitalization ofentity) ÷ (book va lue of shareholders fund).Tax savings = Statutory tax rate -Effective tax rate.Statutory tax rate = flat rate as mandated by the Ghana Revenue Authority.Effective tax rate = Corporate income tax expense/profit before tax.Sgrowth (sales growth) = (Previous Sales revenue -Current sales revenue) ÷Previous sales revenue.Fsize (firm size) = Natural log of firm's total assets.fLev (Financial leverage ) = Long term debt/shareholders fund.Age (Age of firms) = log(the difference between the year of establishment and years of observation).4. Results and DiscussionFigure 1 and Table 1 presents the descriptive statistics for two key variables, namely tax planning of firms and market performance over the twelve year period.Like the statutory rate, tax savings of firms show a decreasing trend. As tax authorities take steps to reduce the tax burden on firms, the leakages in tax revenue due to firms tax planning activities reduce. From figure 1, the statutory tax rate reduced from about 32% to 25%. Tax savings of firms reduced also from 15% to 8% by 2011. That is to say each percentage point decrease in the statutory rate leads to a corresponding decrease in firms' tax planning savings.The policy implication of this finding is two-fold. Firstly, the notion of increasing tax rate in order to rake in more tax revenue may not hold. As tax rates increased, the motivation of firms to deny the state of revenue through intensified tax planning machinery is enhanced. Secondly, as the tax rate is decreased, thenet benefit of planning tax is derailed. The way forward for tax revenue optimisation is to maintain lower tax rates and drag more firms into the tax net.Table 1 provides the market performance of the firms over the twelve year period.The farther the Tobin's Q is from unity, the better the company performance. From Table 1, all the company groups recorded an average score higher than 1.00. The overall average score is 1.78 (the median represents the average as skewness is negative). The high average market performance by the firms is driven by only the mining sector and the manufacturing companies. All the remaining classes of companies recorded lower than the average score.This finding confirms the observation of business persons in Ghana that business climate in Ghana gives unmatched advantage to the mining sector. The service sector records the lowest market performance. This raises a major concern as the sector is the major contributor to gross domestic product (GDP) in Ghana. Another sector to watch out for is the oil and gas. This sector has the most recent history. It was expected that the high hopes of investors in the sector after the discovery of oil in commercial quantities in Ghana would have positive influence on the performance. It is expected that the sector will be one of the major drivers of firms' market performance in the future.Table 2 provides correlation results on the variables. This result is essential for at least two reasons. Firstly, it shows basic association between the dependent variable (market performance) and theindependent variable. Secondly, it shows if the "so-called" independent variables are indeed independent. In other words, ittests the multicollinearity status of the independent variables. From Table 2, the correlation co-efficient between tax savings and Tobin's Q is 0.112. This is however significant at 0.097. This significant level is compared with the default alpha of 0.05. As rule of thumb, we reject the null hypothesis if the actual significant level is higher than the expected alpha and do not reject if the actual significant is less than the expected alpha. In this instance p-value of 0.097 is greater than the expected alpha of 0.05. The null hypothesis that:H1: There is an association between tax planning and firms' market performance is rejected.The correlation results do not suggest causation but gives an indication of association between the variables. The "no relationship" finding between tax planning and firms' market performance supports the reports of Desai and Dharmapala (2007) but differ from the findings of Desai and Hines (2002) and Abdul-Wahab (2010). The findings suggest that although savings from tax planning reflect in higher profit after tax, it does not necessarily reflect in the pocket of shareholders. This finding ignites studies aimed at uncovering factors that mediate the tax planning-firm performance relationship. Indeed, it might be the reasons behind the works of Desai and Dharmapala (2007), Desai and Dharmapala (2009) and Abdul Wahab (2010).Another finding in table 3 is the relationship between market performance (proxied by tobin's Q) and the firm specific variables. Sales growth and firm size shows positive and significant association with firms' market performance. On the other hand financial leverage and age of the firms shows a negative association with firm performance. The findingsWe do not reject the null hypotheses (H2 and H3) stated asH2: Firm performance and sales growth and firm size are positively associatedH3: Firms age and financial leverage are negatively associated with firms' market performance. Further Table 3 gives an indication that multicollinearity among the independent variables does not exist. The rule of thumb is that if the correlation coefficients between any two of the variables is above 0.50 (either positive or negative), those two variables are multi-correlated and should not be simultaneously included in the regression model. From Table 3, this condition does not exist. The variables can be regressed against the dependent variables.Table 3 shows the regression of Tobin's Q (proxy of firms' market performance) and all the independent variables.The adjusted R2 connotes that the five independent variables explain 55.3% of the variations in the dependent variable. The model is significant at 0.0001. This is a strong indicator that the variables used in the model have sufficiently explained the firms' market performance.The regression results found a relationship that is largely consistent with the correlation results shown in table 3. The results affirm that tax planning plays an insignificant role in the determination of firms' market performance. Again this supports the agency theory's argument that it not all actions of management that help achieve the wealth maximisation objective of management. From the results sales growth and the financial leverage are the two most influential variables. Firms should maintain low financial leverage ratio and pursue sales growth strategies in order to boost their market performance.5. ConclusionsThe study sought to ascertain the level of tax planning offirms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies over a twelve year period from 2000. The longitudinal correlative designed was used. Thefollowing conclusions are reached.Firstly firms' tax savings decrease as tax authorities reduce the statutory corporate income tax rates. This indicates that leakages in tax revenue as a result of intensive tax planning of firms reduce when tax authorities maintain low corporate income tax rates.Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. Agency problem is much present in the issue of tax planning. The efforts of management to reduce tax burden of firms benefit other stakeholders rather than shareholders. There may be other factors that could ensure that substantial benefits of tax planning accrue to shareholders. Some researchers arguably, root for good corporate governance. This falls outside the scope of this study.Finally, sales growth, firm size, age of firms, financial leverage and tax planning simultaneously play a major role in determining firms' market performance. These variables explain 55.3% of the variations in firms' market performance. Sales growth and financial leverage are the two most influential variables that determine firm market performance.References二、文献综述企业纳税筹划文献综述摘要：20 世纪以来并购已经成为企业快速扩张和整合的重要手段之一。

税收政策文献综述09国经1班吴琼32009032121税收政策是指国家为了实现一定历史时期任务，选择确立的税收分配活动的指导思想和原则，它是经济政策的重要组成部分。

本篇文献综述针对我国财政政策的发展历史，发展现状，存在的问题及解决的方向，结合税收政策作为经济政策的一种手段所产生的作用对当前的发展趋势做出总体的概括。

中国税收政策的形成和发展与中国的社会经济建设紧密联系在一起。

不同时期的税收政策有鲜明的时代特点。

建国初期和国民经济恢复时期的税收政策，由于中共七届二中全会决定把党的工作中心从乡村转到城市，以生产建设为中心任务。

因此税收工作重点也开始由农村向城市转移。

此后，中央人民政府有针对性地制定了统一税政、平衡财政收支的总的税收政策。

具体体现在1950年1月中央人民政府政务院发布的《关于统一中国税政的决定》的通令文件。

明确规定了新中国的税收政策、税收制度、管理体制、组织机构等一系列重大原则，建立了新中国第一个统一税收制度。

对于中国财政经济的好转和国民经济的恢复和发展，创造了良好的条件。

1952年底，中国胜利地完成了恢复国民经济的任务。

国营经济和合作经济在整个国民经济中的比重提高了，商品流转和经营方式也发生了变化，同时，认为“多种税、多次征”的复杂税制不利于国家的计划管理和国营企业经济核算。

因此，提出了“保证税收，简化税制”的原则，税收政策开始配合对资本主义工商业的社会主义改造。

综合各类文献，总结中国税收政策的现状，自1994年税制改革，确立了中国的税收基本政策是：统一税法、公平税负、简化税制、合理分权。

建国以来尤其是改革开放二十多年来，在汲取我国传统税收文化中优良因素的基础上，随着财税体制的规范、税收征管的完善、税法的普及以及纳税人和税务人员素质的提高，我国公开、公平、公正的税收法制环境逐步取得成效，良好的税收文化已在我国初步形成。

然而，在向市场经济体制转轨过程中，作为政治文化一部分的税收文化也随着经济体制的变迁而处于变革之中。

本文档包括改专题的：外文文献、文献综述一、外文文献文献信息标题：Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in Ghana 作者：Kawor, Seyram; Kportorgbi, Holy Kwabla期刊：International Journal of Economics and Finance第6卷，第3期，页码：162-168，2014年Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in GhanaKawor, Seyram; Kportorgbi, Holy KwablaAbstractThe study sought to ascertain the level of tax planning of firms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies listed on the Ghana Stock Exchange over a twelve year period from 2000. The longitudinal correlative designed was used. The results indicate that that firms' tendency to engage in intensive tax planning activities reduces when tax authorities maintain low corporate income tax rates. Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. It is concluded that investors must institute systems to ensure tax planning benefits reflect significantly in their pockets.Keywords: Ghana stock exchange, tax planning, market performance, longitudinal correlative design, investors1. IntroductionOver the years and throughout the world, the history of taxation brings out one fact; that taxes are coercive in nature and therefore economic units which are assigned the tax liability never wholly intend to bear the actual tax burden (Commonwealth Association of Tax Administrators (CATA), 2007). Economic units, more specifically, corporate bodies are always adopting ways to minimise, postpone, or avoid entirely, the payment of tax. The attempts by the economic units to reduce, postpone or avoid tax payment can be legal or illegal. The legal means is called tax planning while the illegal means is called tax evasion. The dire consequence of tax evasion makes it an unattractive option for listed companies (Murphy, 2004).The practice of tax planning dates back to 1947 when learned judge Hand, in the case Commissioner v Newman, held that there is nothing sinister in arranging ones affairs so as to keep taxes as low as possible. Hoffman's (1961) tax planning theory supports this argument. According to Hoffman, it is a necessity for firms to understand the prevailing tax laws and apply the laws in a manner that ensures the firms minimise their tax exposure. Hoffman posits that it makes no economic sense to pay more tax than what the law demands. Scholes and Wolfson's (1992) tax planning framework also underscores the need for corporate bodies to engage in tax planning. According to Scholes and Wolfson, a successful company is the one that is properly attuned to its tax environment.International governmental organizations, such as CA TA (2009), suggest that corporate bodies in Ghana, especially the large entities, engage in complex tax planning activities. Research by civil society groups such as Christian Aid (2008), Action Aid (2011), and Dan Watch (2011), confirm this assertions made by the Domestic Revenue Division. The missing element in the findings is thequantitative expression of the tax planning activities of the firms.The traditional thinking is that firms that derive maximum benefit from tax planning perform better than those that do not plan their taxes (Murphy, 2007). From the empirical perspective, tax planning is positively associated with firms' performance. For instance, Desai and Hines (2002); Chen, Chen, Chen and Shelvin (2010) reported positive association between tax planning savings and firm performance. The argument is that tax represents cost of doing business, and any action that has the potential of minimising tax cost reflects in higher firm performance. This argument presupposes that tax planning cost and risk does not exceed the savings from the planning.Few studies in the UK dispel the traditional relationship between tax planning and firm performance. While admitting that tax planning has a positive association with accounting performance, Desai and Dharmaphala (2007) reported that tax planning has a neutral association with market performance. Indeed Abdul-Wahab (2010) found a negative association between tax planning and firm performance. Kportorgbi (2013) suggested that corporate governance strength plays a mediating factor in the tax planning-firm performance relationship.A study of the effect of tax planning savings on firms' market performance is crucial for all stakeholders in the emerging security markets such as the Ghana stock Exchange. In fact each possible relationship has a unique implication for the players. For instance, a positive association implies that tax planning produces a win-win situation for both management and shareholders (investors). A negative association connotes that tax planning benefits may not eventually trickle to the pocket of the shareholder. Indeed, a negative association may be an indicative of the existence of agency problem, where management is inclined to pursue tax planning to enhance their own lot rather than advancing the interest of the investor. Where a neutral association is established, it will invoke a follow up study on the possible factors that could influence the relationship either positively or negatively. Secondly, the study is necessary to inform tax planning agents and investors on the dynamics of tax planning1.1 Objective of the StudyThe primary objective of this study is to explore the relationship between tax planning savings of firms listed on the Ghana Stock Exchange and firm market performance. The study also seeks to examine the simultaneous influence of other firm specific variables on the tax planning-market performance relationship.1.2 Tax Planning Intensity of Firms in GhanaCommentators on tax behaviour of firms in Ghana paint a picture that suggests that large firms engage in tax planning activities. For instance CATA (2009) posits that Ghana Revenue Authority lost seventy-four million pounds between 2005 and 2007 to the European Union (EU) in tax revenue as a result of tax avoidance by several multinational companies. Murphy (2004) also reported that firms have complex gamut of arsenals to reduce their tax burden. The reports indicate that the tax avoiding mechanism of firms are largely allowed by the tax laws. There are also indications that the firms take advantage of the loopholes in the tax laws to derive unintended tax benefits. The avenues for tax planning usually revolve around locational reliefs, industry-specific concessions and capital allowance provitions. Others are time variables and entity variables.Most of the reports are not precise in their estimation of the benefits that firms achieve through tax planning. The lack of precision in measuring tax planning intensity is largely attributed to the insufficient reporting of issues of taxation by firms. Aside the mandatory disclosures to tax authorities, firms are reluctant in disclosing much on tax behaviours. This is due to the perceivedthin line that exist between tax planning and tax evasion. Listed companies, however, provide provide adequate information necessary to estimate the tax savings of the firms. This is made possible by virtue of the financial reporting guidelines provided by the security exchange commision.2. Review of Related LiteratureThis section is subdivided into theoretical review and empirical review. The theoritical review encapsultes the Hoffman's (1961) tax planning theory. Three main empirical studies are reviewed. They are Desai and Hines (2002), Desai and Dharmaphala (2009) and Abdul-Wahab (2010).2.1 Hoffman's Tax Planning TheoryAccording to Hoffman (1961) tax planning seeks to divert cash, which would ordinarily flow to tax authorities, to the corporate entities. Tax planning activities are desirable to the extent that they reduce taxable income to the barest minimum, without sacrificing accounting income. The theory is premised on the fact that firms tax liability is based on taxable income rather than accounting income. The idea is thus to intensify activities that reduce taxable income but has no indirect relationship on accounting profit. The theory thus recognised a positive association between firm tax planning activity and firm performance.Hoffman (1961) also recognised the role of tax cost in the tax planning activities. The theory thus provided that the positive association between tax planning and corporate performance is on a basic assumption that tax benefits from the tax planning exceed tax cost. The scope of the Hoffman's tax planning theory does not address the dynamics of tax planning and market performance. As capital markets develop and the separation of ownership and control of corporate bodies become well-spread, the need for a comprehensive tax planning theory is imperative. This need is rather addressed through the empirical perspective than through theoretical perspective (Inger, 2012).2.2 Empirical Review and Development of HypothesisDesai and Hines (2002) provide evidence on firm performance and tax planning behaviour of firms. Again, the study investigates the relationship between tightening of tax systems and market value of firms. The study was based on 850 listed US firms. The study sample was purposively selected to reflect the characteristics desired by the researchers. The study was cross sectional and the data relates to year 2000. Correlative-description design was adopted. Simple regression and t-tests were used to establish the relationships. Desai and Hines established that intensive tax planning is associated with higher firm performance. On the other hand, the study reported that tightening of the tax system is positively associated with higher market performance of firms. The findings of Desai and Hines (2002) are similar to that reported by Chen, Chen and Chen (2010). Desai and Dharmapala (2007) provided a comprehensive study that incorporates tax planning, corporate governance and firm performance. The study used 4,492 observations on 862 firms over the period 1993 to 2001. This panel data was drawn from the Compustat and Execucomp databases, merged with data on institutional ownership of firms from the CDA/Spectrum database. Firms' performance is measured using Tobin's q and governance quality is proxied by the level of institutional ownership. Tax planning is measured by inferring the difference between the income reported to capital markets and tax authorities (the book-tax-gap). Two analysis models were adopted-the OLS model and the IV estimation model. The OLS results shows that the average effect of tax planning on corporate performance is not significantly different from zero. In other words, there is no relationship between tax planning and firm performance. The study howeverreports a positive association between tax planning savings and performance for well-governed firms. Desai and Dharmapala (2007) thus concluded that corporate governance mediates the tax planning-firm performance relationship. The IV estimate shows a higher effect of corporate governance on firm performance.Abdul-Wahab (2010) provides a result that differs from the findings of Desai and Hines (2002), Desai and Dhamarpala (2009), and Chen, Chen, Chen and Shelvin. Abdul-Wahab's (2010) study sought to establish a relationship between tax planning savings of firms and their value. The study simultaneously investigates the moderating influence of corporate governance. Abdul-Wahab's study employed 240 firms listed on the London stock exchange from 2005 to 2007. Tax planning was proxied by the difference between the effective tax rate of the entities and the applicable statutory tax rates. Self-constructed governance index was constructed using corporate governance mechanisms. Firms' value was represented by the Tobin's Q. The data was analysed using panel regression analysis model. As a check, the OLS model was also used.The results indicate a negative relationship between firm value and tax planning activities. Abdul-Wahab (2010) explains the relationship with reference to tax planning cost and risk. The study suggested that tax planning cost and risks associated with tax planning have the potential of derailing the benefits that should have accrued to shareholders. The researcher maintains that as tax planning activities increase, the tax costs and risks outweighs the benefits.Due to the diversity of the relationships found between tax planning and firms' market performance, it is right to develop a null hypothesis as:H1: There is an association between tax planning and firms' market performance.It is unreasonable to suggest that tax planning is the only determinants of firm performance. Baring the existence of multicollinearity between (among) the explanatory variables, sales growth, financial leverage, firm size and age of the firms will be introduced into the regression models. Several studies, including Desai and Hines (2002), Desai and Dharmaphala (2007), Abdul-Wahab (2010) reported positive association between firm performance and sales growth, firm size and financial leverage. It is thus clear to develop the null hypothesis that:H2: Firm performance and sales growth and firm size are positively associated.Firms' age, according to Desai and Dharmapala (2007) and Abdul-Wahab (2010) has a negative association with market performance of firms. This gives rise to the third null hypothesis that:H3: Firms age and financial leverage are negatively associated with firms' market performance. 3. MethodologyLongitudinal correlative design is adopted for the study. Longitudinal design is essential if the same research entities sampled in a cross section are then re-sampled at different times (Creswell, 2009; De Vaus, 2001). According to the authors, the design helps overcome limitations associated with the "snap shot" approach of cross sectional designs.The study population comprises all non-financial firms listed on the Ghana stock exchange. As of June 2013, twenty-three (23) out of thirty-five (35) firms listed on the Ghana Stock Exchange were non-financial companies. Financial companies are excluded from the population. Previous researchers posit that the financial sector is a highly regulated sector and as such regulations blur the relationship that exist among the variables to be studied (O'Hamon & Taylor, 2007; Desai & Dharmapala, 2009; Abdul-Wahab, 2010).The study uses a panel data for twelve-year period, from 2000 to 2011. Data for the study is collected from the database of the Ghana Stock Exchange. Panel regression model is adopted fordata analysis and the Ordinary least square (OLS) been the method of regression.The regression model is summarized as: (1)α = (alpha) shows the constant affecting net profit margin on corporate tax.Tobin's q (market performance) = (market capitalization of entity) ÷ (book value of shareholders fund).Tax savings = Statutory tax rate -Effective tax rate.Statutory tax rate = flat rate as mandated by the Ghana Revenue Authority.Effective tax rate = Corporate income tax expense/profit before tax.Sgrowth (sales growth) = (Previous Sales revenue -Current sales revenue) ÷Previous sales revenue.Fsize (firm size) = Natural log of firm's total assets.fLev (Financial leverage ) = Long term debt/shareholders fund.Age (Age of firms) = log(the difference between the year of establishment and years of observation).4. Results and DiscussionFigure 1 and Table 1 presents the descriptive statistics for two key variables, namely tax planning of firms and market performance over the twelve year period.Like the statutory rate, tax savings of firms show a decreasing trend. As tax authorities take steps to reduce the tax burden on firms, the leakages in tax revenue due to firms tax planning activities reduce. From figure 1, the statutory tax rate reduced from about 32% to 25%. Tax savings of firms reduced also from 15% to 8% by 2011. That is to say each percentage point decrease in the statutory rate leads to a corresponding decrease in firms' tax planning savings.The policy implication of this finding is two-fold. Firstly, the notion of increasing tax rate in order to rake in more tax revenue may not hold. As tax rates increased, the motivation of firms to deny the state of revenue through intensified tax planning machinery is enhanced. Secondly, as the tax rate is decreased, the net benefit of planning tax is derailed. The way forward for tax revenue optimisation is to maintain lower tax rates and drag more firms into the tax net.Table 1 provides the market performance of the firms over the twelve year period.The farther the Tobin's Q is from unity, the better the company performance. From Table 1, all the company groups recorded an average score higher than 1.00. The overall average score is 1.78 (the median represents the average as skewness is negative). The high average market performance by the firms is driven by only the mining sector and the manufacturing companies. All the remaining classes of companies recorded lower than the average score.This finding confirms the observation of business persons in Ghana that business climate in Ghana gives unmatched advantage to the mining sector. The service sector records the lowest market performance. This raises a major concern as the sector is the major contributor to gross domestic product (GDP) in Ghana. Another sector to watch out for is the oil and gas. This sector has the most recent history. It was expected that the high hopes of investors in the sector after the discovery of oil in commercial quantities in Ghana would have positive influence on the performance. It is expected that the sector will be one of the major drivers of firms' market performance in the future.Table 2 provides correlation results on the variables. This result is essential for at least two reasons. Firstly, it shows basic association between the dependent variable (market performance) and theindependent variable. Secondly, it shows if the "so-called" independent variables are indeed independent. In other words, it tests the multicollinearity status of the independent variables. From Table 2, the correlation co-efficient between tax savings and Tobin's Q is 0.112. This is however significant at 0.097. This significant level is compared with the default alpha of 0.05. As rule of thumb, we reject the null hypothesis if the actual significant level is higher than the expected alpha and do not reject if the actual significant is less than the expected alpha. In this instance p-value of 0.097 is greater than the expected alpha of 0.05. The null hypothesis that:H1: There is an association between tax planning and firms' market performance is rejected.The correlation results do not suggest causation but gives an indication of association between the variables. The "no relationship" finding between tax planning and firms' market performance supports the reports of Desai and Dharmapala (2007) but differ from the findings of Desai and Hines (2002) and Abdul-Wahab (2010). The findings suggest that although savings from tax planning reflect in higher profit after tax, it does not necessarily reflect in the pocket of shareholders. This finding ignites studies aimed at uncovering factors that mediate the tax planning-firm performance relationship. Indeed, it might be the reasons behind the works of Desai and Dharmapala (2007), Desai and Dharmapala (2009) and Abdul Wahab (2010).Another finding in table 3 is the relationship between market performance (proxied by tobin's Q) and the firm specific variables. Sales growth and firm size shows positive and significant association with firms' market performance. On the other hand financial leverage and age of the firms shows a negative association with firm performance. The findingsWe do not reject the null hypotheses (H2 and H3) stated asH2: Firm performance and sales growth and firm size are positively associatedH3: Firms age and financial leverage are negatively associated with firms' market performance. Further Table 3 gives an indication that multicollinearity among the independent variables does not exist. The rule of thumb is that if the correlation coefficients between any two of the variables is above 0.50 (either positive or negative), those two variables are multi-correlated and should not be simultaneously included in the regression model. From Table 3, this condition does not exist. The variables can be regressed against the dependent variables.Table 3 shows the regression of Tobin's Q (proxy of firms' market performance) and all the independent variables.The adjusted R2 connotes that the five independent variables explain 55.3% of the variations in the dependent variable. The model is significant at 0.0001. This is a strong indicator that the variables used in the model have sufficiently explained the firms' market performance.The regression results found a relationship that is largely consistent with the correlation results shown in table 3. The results affirm that tax planning plays an insignificant role in the determination of firms' market performance. Again this supports the agency theory's argument that it not all actions of management that help achieve the wealth maximisation objective of management. From the results sales growth and the financial leverage are the two most influential variables. Firms should maintain low financial leverage ratio and pursue sales growth strategies in order to boost their market performance.5. ConclusionsThe study sought to ascertain the level of tax planning of firms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies over a twelve year period from 2000. The longitudinal correlative designed was used. Thefollowing conclusions are reached.Firstly firms' tax savings decrease as tax authorities reduce the statutory corporate income tax rates. This indicates that leakages in tax revenue as a result of intensive tax planning of firms reduce when tax authorities maintain low corporate income tax rates.Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. Agency problem is much present in the issue of tax planning. The efforts of management to reduce tax burden of firms benefit other stakeholders rather than shareholders. There may be other factors that could ensure that substantial benefits of tax planning accrue to shareholders. Some researchers arguably, root for good corporate governance. This falls outside the scope of this study.Finally, sales growth, firm size, age of firms, financial leverage and tax planning simultaneously play a major role in determining firms' market performance. These variables explain 55.3% of the variations in firms' market performance. Sales growth and financial leverage are the two most influential variables that determine firm market performance.References二、文献综述企业纳税筹划文献综述摘要：20 世纪以来并购已经成为企业快速扩张和整合的重要手段之一。

205税务筹划研究综述张瑜作者简介：张瑜（1995—），女，汉，陕西延安人，在读研究生，延安大学，研究方向：税法与税务筹划。

（延安大学陕西延安716000）摘要：近些年来，有关于对税务筹划的研究已经不再局限于以往的理论研究，在实践方面也取得了十分可观的成绩。

但是据实来说，我国对于税务筹划的研究相比于国外的研究还是略显不足。

本文对有关于税务筹划的若干文章进行了梳理，期望可以给国内税务筹划的研究提供些许借鉴。

关键词：税务筹划；研究简述；述评一、引言依据税法进行纳税是我国每一个公民都应当尽的义务。

税务筹划能够直接减少税金，增加企业的可流动资金，从而能够使企业在市场中拥有更多的主动权。

所以，税务筹划得到了广泛关注。

税务筹划是什么、税务筹划应该达到什么样的目的、税务筹划有哪些具体的方法，这些都需要学者们来进行研究。

二、国外税务筹划研究简述伴随着政府开始征收税金，人民以及企业想要降低税负的想法也就随之而来。

税务筹划先是在国外发展起来的，但是它发展的道路并不是一帆风顺的。

税务筹划一开始并不为人们所接受，经历的曲折的过程才慢慢发展道路现在的被承认。

发展过程经历了两个阶段。

（一）传统税务筹划理论阶段税务筹划先是在国外一些发达国家中发展起来的。

1935年Tomlin 发表了声明，指出“无论是谁都有权利在法律所允许的范围之内安排自己的日常活动，即便是为了使自己需要缴纳的税负减少，虽然说这不是政府和人们所提倡的，但是政府没有理由认为这种行为是不合法的，不应该受到指责。

”［1］威斯特敏斯特诉讼一案之后，税务筹划才被国外的法律承认，自此，税务筹划理论得到了广泛而科学的研究。

早期的税务筹划研究，把着眼点放在考察与税务相关的管理行为上，如Morrison Thomas A．＆Buzby Stephen L．（1968）等研究的是税收如何影响特定的管理决策；Crumbley D．Larry （1973）从行为学角度研究税收问题。

文献综述（20_ _届）新企业所得税下纳税筹划及风险研究由于近年来，纳税筹划在我国被越来越多的企业所重视，使其得到了很快的发展，各种形式的税收筹划活动也已在各地悄然兴起。

但是税收筹划是一项系统工程，该项活动在给企业带来节税收益的同时也蕴涵着风险，即风险与利益是并存的，如果无视这些风险，任其发生而不加以防范，势必有悖税收筹划的初衷，其结果可能是以节税目的为开始，却以遭受更大的损失而结束。

新税法的颁布和实施必定会对企业纳税筹划产生一定的影响并带来新的涉税风险，对这方面的研究将有利于企业调整纳税筹划方略，降低其风险。

1 新旧企业企业所得税主要对比2007年3月16日中华人民共和国第十届全国人民代表大会第五次会议通过了《中华人民共和国企业所得税法》，并从2008年1月1日起施行。

新税法取代了1991年4月9日公布的《外商投资企业和外国企业所得税法》和1993年12月13日公布的《企业和外国企业所得税暂行条例》。

蓝希华(2007)将新企业所得税法的特点归结为“统一”与“过渡”。

其中“统一”表现在(1)内资、外资企业都适应新的企业所得税法；(2)统一实行25%的税率；(3)统一税前扣除办法和标准；(4)统一税收优惠政策。

“过渡”表现在对老企业规定了一个五年的过渡期。

王海永、金菁(2008)通过表格和制图的方式清晰的展示了新旧企业所得税的主要不同之处，并且指出新企业所得税的制定和实施标志着新企业所得税制度更具有科学性、规范性和国际性,对推进我国社会主义市场经济建设,促进改革开放和社会主义和谐社会的建立都具有深远的意义。

由于中国经济的飞速发展，企业类型和企业体制与90年代相比已有了巨大的变化，旧税法在某些方面已不再适应，新税法的出台更加符合我国企业的现状，有利于与国际接轨。

2 纳税筹划理论2．1 纳税筹划产生及原因纳税筹划是历史发展到一定阶段的产物，该现象的首次出现可以追溯1935年，英国上议院议员汤姆林爵士对“税务局长诉温斯特大公”一案，作了有关纳税筹划的声明：“任何一个人都有权安排自己的事业，依据法鲁这样可以少缴税”。

税收筹划文献以下是一些关于税收筹划的文献推荐：1. Desai, M. A. (2003). The logic of international restructuring. Journal of Financial Economics, 68(1), 33-62.该文献研究了跨国公司的国际税收筹划行为，并探讨了它们与公司业绩之间的关系。

2. Hines, J. R., & Rice, E. M. (1994). Fiscal paradise: Foreign tax havens and American business. The Quarterly Journal of Economics, 109(1), 149-182.这篇文章分析了美国企业使用海外避税天堂的情况，并讨论了这种行为对税收筹划的影响。

3. Hanlon, M., & Heitzman, S. (2010). A review of tax research. Journal of Accounting and Economics, 50(2-3), 127-178.该文献对税收研究的现有文献进行了综述，包括税收筹划的相关研究。

4. Dowd, T. J., & Daiber, A. F. (2002). Corporate domicile and average effective tax rates: The cases of tax haven and other countries. Journal of International Accounting, Auditing and Taxation, 11(2), 93-113.这篇研究探讨了公司所在国家对公司平均有效税率的影响，特别关注了税收天堂和其他国家。

5. Blouin, J. L., & Raedy, J. S. (2009). Tax-induced earnings management by firms with net operating losses. Journal of Accounting and Economics, 47(1-2), 61-83.该研究探讨了在有净营业亏损的情况下，企业如何通过税收筹划来进行盈余管理。