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oecd国家研发税收优惠的趋势与问题.pdf

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1、SCIENCE TECHNOLOGY INDUSTRY S T I TAX INCENTIVES FOR RESEARCH AND DEVELOPMENT: TRENDS AND ISSUES 2 FOREWORD An increasing number of OECD governments are offering special fiscal incentives to business to increase spending on research and development (R G120 Form of tax incentive - R 5 G120 R G120 Tar

2、geted incentives - popular targets for R G120 Definition of R G120 Avoidance provisions - special provisions can prevent firms from avoiding taxes by claiming unwarranted R and G120 Foreign firm eligibility - R the number of large firms and the average size of enterprises; the availability of techni

3、cal personnel and an adequate science and technology (S the extent of international openness and links to the world economy; the level of government expenditures on basic research; the channels between public and private research efforts; the extent of intellectual property protection, etc. The rela

4、tive role of these factors in determining a countrys R BERD = business expenditures on research and development ; DPI = business value-added. Source: OECD. 12 DESIGN OF FISCAL INCENTIVES FOR R ii) tax allowances or extra amounts over current business expenses deducted from gross income to arrive at

5、taxable income; and iii) tax credits or amounts deducted from tax liability. The fiscal incentives now in place in the OECD vary widely in their form and other features of their design. Some general trends can be identified. More countries are introducing R and ii) unused tax allowances may be carri

6、ed forward to offset future tax under normal loss carryforward provisions, while the carryforward of unused tax credits requires the creation of a special pool to track unused credits. 15 Table 2. R or a cap on the maximum amount of the tax incentive that can be deducted. These tax provisions also v

7、ary as to whether the amounts gained are themselves taxable or not. The majority of OECD countries with R ii) the increment of R evaluations show that R G120 national content provisions - there must be a certain amount of national content associated with the R G120 exploitation provisions - the resu

8、lts of R and G120 IPR provisions - the intellectual property rights (IPR) resulting from the R&D are owned by the country providing the tax incentive. For example, Canada and the United States maintain provisions that the R&D must be performed in the country to be eligible for tax incentives. Howeve

9、r, expenses incurred by national firms or foreign subsidiaries on R&D projects performed outside the country (e.g. salaries, travel costs of researchers) are not eligible. Other countries extend incentives to their enterprises which conduct R&D in foreign jurisdictions. Australia has both national content and exploitation provisions: key research staff must be Australian nationals and the benefits from R&D must be applied within Australia.

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