Foreign real estate tax generally includes property tax and real estate tax, and the scope of collection is very wide. Most countries collect it by the whole people, but generally they will exempt non-profit organizations such as government, religion and charity, set up certain tax exemptions for houses occupied by families, and give certain credits to low-income families.
Real estate tax is a kind of property tax, which is taxed according to the value of real estate. In some countries, the value of real estate is levied according to the price at the time of real estate transaction, but it will be reassessed every few years; Some countries levy real estate at market price every year.
The tax base rate of foreign real estate tax is often adjusted in time. In the United States, on the one hand, the property tax is levied according to the evaluation price, and the tax base moves forward with the fluctuation of the housing market and is adjusted accordingly. On the other hand, the tax rate is opposite to the economic boom: during the economic boom, the real estate price rises and the tax source is abundant, and the government will lower the tax rate; In the economic downturn, tax sources are scarce, and the government needs to raise tax rates to make up for the fiscal deficit. In order to simplify the evaluation procedure, many developed countries have established a complete database of real estate transactions, and the approximate market value of a specific property can be easily obtained through pre-designed procedures. These practices have effectively promoted the management and collection of property tax.
Highlight public welfare and curb real estate speculation
In foreign countries, the most important purpose of collecting real estate tax is to ensure that local finance has sufficient sources, which generally accounts for about 70% of local fiscal revenue. People in foreign countries seldom complain about real estate tax, the important reason is that foreign real estate tax is mainly used for public expenditure, such as gardens, fire protection, education, public transportation, museums and other fields, which are taken from the people and used by the people.
Generally speaking, where the real estate tax rate is high, the quality of public facilities and services is better than other regions. For example, the grades in primary and secondary schools are relatively high. In some areas, tuition fees are free from kindergarten to high school, and students are provided with free lunches and school buses. In the United States, the collection of property tax in a region can be decided by taxpayers in the jurisdiction. If taxpayers think they don't need more public services, they can propose to cut some budgets through the representatives of public opinion in their constituencies, so as to pay less property taxes.
Suppressing real estate speculation and controlling house prices are not the main functions of foreign real estate taxes, but due to the scientific and reasonable setting of the collection and management links, it will play a positive role in regulating the real estate market price to a certain extent.
In foreign countries, relying on property tax regulation has both successful examples and failed examples. At the beginning of this century, in order to curb the bubble in the real estate market, South Korea raised the tax burden of property tax several times, which led to the owners of some high-priced areas bearing large property taxes, but failed to effectively stimulate the real estate circulation in these areas and restrain the housing prices, and finally ended in failure. Singapore raises high real estate taxes on developers and the rich, while providing housing units and prices controlled by the government for low-and middle-income families, and giving other vulnerable groups more preferential housing policies. Differential property tax will help Singapore effectively curb the rise in housing prices and protect residents' housing.
United States: Real estate tax highlights the characteristics of "public finance"
The real estate tax in the United States is levied in the process of property ownership, which has the remarkable characteristics of strong correspondence between revenue and expenditure, tax burden and public services, showing strong vitality. After long-term implementation and continuous improvement, it has now developed into the core part of American property tax.
Property tax has become the main source of income for local governments.
American property tax is the main self-owned financial resources of local governments in the United States. In American history, it even accounted for the vast majority of local governments' income, and it has obvious characteristics in the collection method and tax rate determination.
First of all, the scale of real estate tax is levied by the whole people, which is the main source of local government income and the second largest expenditure of residents on residential consumption. Real estate tax is based on the approved value of real estate. The approved value consists of two parts, one is the value of the house itself, which is mainly based on the value at the time of purchase, the added value of decoration and the added value of the market. ; The second is the value of land. The local government takes a certain proportion of the approved value of real estate as the taxable value, and then determines the real estate tax rate, which is generally 1%-3%. The actual amount of real estate tax paid is the real estate tax value multiplied by the real estate tax rate.
Secondly, the United States uses different methods to evaluate real estate. First, the market comparison method, that is, taking the market value of similar real estate as a reference, evaluates the evaluated real estate, which is generally applicable to the evaluation of relatively simple residential types; Second, the cost accounting method, that is, the construction cost and depreciation are used to evaluate the value of real estate, which is generally used to evaluate large public buildings, such as playgrounds, sports grounds, cinemas, airports, hospitals, etc. The third is the income analysis method, that is, according to the rental income, the market value of real estate is calculated through the return on investment. This method is generally used for the evaluation of real estate such as commercial leasing.
Third, the real estate tax rate in the United States often changes. The total tax rate of real estate is the sum of local tax rates at state and sub-state levels, which generally consists of state tax rate, city and county tax rate and school district tax rate. After 1990s, the state government's property tax has been greatly reduced, mainly attributed to local governments, accounting for about 85%-90% of the local government's fiscal revenue. Local governments at all levels determine that the real estate tax rate is subject to state tax laws and can only be implemented after obtaining the approval of the state government.
Special groups that implement nuclear four enjoy preferential treatment.
The evaluation of real estate value in the United States is separated from the collection and management of real estate tax. The value assessment is completed by the tax collector, and the tax collector is responsible for the collection and management. As for the assessment of real estate tax, the shanghai real estate appraisers association (SR E A) was established in 1935, and it is the largest independent organization of real estate appraisers in North America, and professional tax collectors assess the value of real estate. If the taxpayer disagrees with the valuation, he can file a reconsideration or appeal. In terms of tax management system, the United States has established a private property registration system, which is relatively complete and convenient for standardized management. It is also matched with the personal credit information system and the real-name deposit registration system to facilitate the tax authorities to grasp taxpayer information. Using the network management of real estate information, real estate appraisal can pay taxes online.
American property tax collection procedures are as follows. First of all, tax officials check the taxable value of real estate at a specified time, usually once a year; Then the municipal and town governments determine the tax rate according to the taxable value of real estate and the financial budget, and the tax authorities will implement it; Finally, the tax official calculates the tax amount, and notifies the taxpayer by email or sends it to the relevant financial department for payment by computer.
Professor Chen Jie, executive deputy director of the Institute of Real Estate of Shanghai University of Finance and Economics, said that every time a payment deadline is exceeded, a fine of 10% of the tax will be paid; If the real estate tax is not paid for five consecutive years, the property will be confiscated and auctioned by the government. Therefore, although the housing price in the United States is cheap, the average purchase price is 220,000-250,000 dollars, but light energy can't afford a house, and it is necessary to pay property tax continuously to truly become a homeowner. Before the collapse of the Detroit property market, many single-family houses sold for only a few dollars, most of which were owners who were unable to pay property taxes and owed huge property taxes because of unemployment, so they had to auction at low prices.
In the process of collection, the United States has also implemented various real estate tax preferential policies for special groups. For example, real estate owned or occupied by government departments, non-profit organizations, educational organizations and religious organizations is exempt from property tax; Property owned or occupied by the government is exempt from real estate tax; States in the United States implement a certain amount of tax exemption for self-occupied houses, and the tax exemption amount varies from state to state. The credit system is implemented for the elderly, the disabled, low-income property owners, retired soldiers and their spouses, agricultural land and other vulnerable groups, and some personal income tax or retirement cash can be deducted or refunded.
Property tax revenue is mainly used for public utilities.
American property tax is the main source of funds needed by local government agencies and plays a vital role in the normal operation of government departments. The tax revenue of real estate tax is mainly used for public utilities.
In the United States and major western countries, house ownership tax is levied in the column of property tax. Property taxes are all local taxes, which are formulated by local governments themselves. The 50 states in the United States levy property tax, and the tax collectors are the county government, the municipal government and the school district government (the most special financial entity in the United States), while the federal and state governments do not levy property tax.
Take San Francisco as an example. During the period of 20 10-20 1 1%, 57% of the property tax collected at the fixed real estate tax rate 1% was controlled by the county and city governments in San Francisco, 25% by the Education Development Foundation, 7.7% by the San Francisco school district government and 3% by UNICEF. 2.5% is led by the Public Places Foundation, 65,438+0.44% is led by the San Francisco Community College, 0.63% is submitted to the Bay Area Expressway Committee, and 0.265,438+0% is contributed to the Bay Area Air Quality Control Committee. In addition, many small full-time committees and public funds have been allocated in advance.
Three aspects draw lessons from the experience of real estate tax collection in the United States.
Hu, dean of the Institute of Public Policy and Governance of Shanghai University of Finance and Economics, and other experts believe that we can learn from American experience from the following three aspects and formulate principles and methods of real estate tax collection and management suitable for China's national conditions.
First of all, give priority to local governments, and hand over the collection rights and tax rules to local governments, because local governments are the most grounded and know the actual public service needs of residents and the related financial input gap. The "local" level can start from prefecture-level cities (municipalities directly under the Central Government are first-level units), and district-level units can also apply for fine-tuning the tax rate and exemption amount of property tax according to local conditions.
Secondly, pay attention to the fairness and feasibility of tax burden, and set up a reasonable exemption area or quota. Foreign property tax has no tax-free area for real estate, but it has tax-free quota, which is more reasonable than tax-free area. In view of the fact that more than 40% of the properties in Chinese cities are reformed houses, and the property value is high, but the income of the owners is not necessarily high, in order to reduce the difficulty of promotion, a certain amount of exemption can be designed according to the family.
Finally, the tax rate is appropriate and the tax burden is increasing. The tax rate can have local flexibility. In principle, how to optimize should be balanced by local governments, but the central government should regulate it in the early stage and set up a demonstration and benchmarking effect. At the same time, in order to reduce the collection resistance and the increase of property tax, all kinds of operating taxes and fees in real estate transactions should be abolished as much as possible.
Germany: real estate tax classification collection controls housing prices
German real estate tax mainly collects real estate transaction tax, which has a heavy tax burden on the transaction link and a light tax burden on the holding link, and has an obvious effect on restraining real estate speculation. Experts believe that China can learn from the German practice of distinguishing between short-term holding and long-term holding, and treating tax collection and exemption differently, so as to achieve the goal of effective taxation and successfully curb higher housing prices.
Classified collection is simple and easy to operate.
German real estate tax is divided into two categories: transaction tax and retention tax. Transaction tax mainly includes land transaction tax and capital gains tax, while retention tax is mainly land tax, and its collection system is simple and easy to operate.
First of all, as a special turnover tax, land transaction tax is mainly paid by the land transferor and transferee, and the tax object is the transfer of real estate in Germany. The tax basis is generally the transaction price. If the transaction price does not exist or cannot be determined, it should be based on the appraised value of real estate in accordance with the relevant provisions of the German Assets Appraisal Law, which is generally 60% to 80% of the market value. In order to encourage residents to own their own houses and crack down on the speculation of real estate speculators, the German government has repeatedly adjusted the land transaction tax rate. The general tax rate of 20 10 land transaction tax is 3.5% to 5%, and the state government where the land is located can specifically determine the applicable tax rate.
Secondly, in terms of capital gains tax, the German government regards tax measures as the basic means to regulate the real estate market. Except for the land transaction tax, the real estate sold is taxed according to the progressive personal income tax standard, and the income from selling the real estate that has been owned for more than 10 years is not taxed. If the capital obtained from the sale of real estate is used to purchase another substitute real estate, it shall be exempted from capital gains tax.
In addition, in the land tax link, self-use houses and non-rental houses do not need to pay property tax, but only land tax on homestead. Land tax is actually a tax levied by the German government on real estate (including land and ground buildings), and the tax amount is determined according to the status and value of registered real estate. The tax basis is the tax standard value determined according to the tax assessment method at the beginning of each year (the tax value of similar land is obtained according to the price of the land sold), and it is paid once a year. German cities and towns still have a lot of room for land tax regulation, so they can formulate appropriate tax rates.
"Paying more attention to transactions than holding" is tax-free for Pratt & Whitney residents.
German real estate tax system has the characteristics of attaching importance to the transaction link, ignoring the holding link, imposing heavy taxes on short-term transactions, exempting long-term holding transactions from taxes, and embodying the principle of tax fairness.
Germany puts the real estate tax in the transaction link, which collects both transaction tax and income tax, and treats it differently according to the length of holding. The transfer held for less than 65,438+00 years is subject to capital gains tax, while the transfer held for more than 65,438+00 years is exempt from tax. It is conducive to curbing short-term real estate transactions, promoting long-term holding and reducing market speculation.
The real estate tax in real estate holding is mainly for commercial real estate, and residents' houses are tax-free; Residents' basic housing only pays construction land tax, and tax incentives and financial subsidies for both construction and purchase are implemented, which reflects the policy intention of protecting residents' housing consumption.
German real estate prices have been stable for a long time. According to statistics, in the 30 years since 1977, the average house price in Germany has only increased by 60%, while the average annual increase is only 2%. If you deduct the price increase factor, the house price in Germany is actually shrinking.
In terms of tax exemption, public land (such as parks and cemeteries), government land and buildings, federal railways, churches, hospitals, scientific research and education institutions, military facilities, municipal companies, etc. enjoy the land tax exemption policy. For a long time, the German government has attached great importance to the basic needs of residents for real estate, and treated the sales and operation of real estate strictly differently. The first house (excluding the resort) does not need to pay property tax, but only collects land tax on the housing base.
Enlightenment of German Real Estate Tax System
Professor Zhu from School of Economics and Management, Shanghai University of Finance and Economics believes that German real estate tax is close to that of China, emphasizing the transaction link and neglecting the retention link. Its real estate tax policy gives us the following enlightenment.
First of all, Germany regards real estate as an important part of the social welfare mechanism, and ensuring residents' housing is one of the primary policy objectives of the federal government. Tax incentives and financial subsidies are implemented for the purchase of houses, and real estate tax is levied in the transaction. Moreover, according to the realization of transactions and the taxation of profits, it embodies the concept of tax increase and the principle of affordability, encourages residents to buy houses and hold them for a long time, and inhibits speculation.
Second, maintaining the stability of German real estate prices is related to the adoption of annual rent system instead of land lease. Due to the adoption of the annual rent system of land use rights, as well as the state's tax incentives and financial subsidies for houses under construction and just needed, the cost of real estate has been reduced and the price has been controlled.
The third is to ensure basic housing for residents. Germany's real estate tax system does not tax residents' houses, but gives tax incentives and financial subsidies to houses built and just bought, which shows special concern for people's livelihood.