直播电商税收征管的制度困境与治理路径

Tax Administration of Live-Streaming E-Commerce: Institutional Predicament and Governance Pathways

摘要: 直播电商作为数字经济与零售业态深度融合的新兴商业模式，近年来市场规模急剧扩张，但其税收征管领域呈现出显著的制度滞后困境。现行规制困境集中体现为纳税主体识别模糊、所得性质归类分歧及征管技术失灵。为此，应超越传统分类所得框架，构建以经济实质为基础的分层认定规则，并依托数智驱动的涉税信息共享与多元协同治理，实现从交易外观穿透至收益本质的精准监管，提升税收治理效能。

Abstract: As an emerging business model characterized by the deep integration of the digital economy and retail sectors, live-streaming e-commerce has experienced rapid market expansion in recent years, yet its tax administration has fallen into a state of systemic institutional lag. The current regulatory predicament is primarily manifested in the blurred identification of taxpayers, divergent classifications of income nature, and the functional failure of tax collection and management technologies. To address these challenges, it is imperative to move beyond the traditional framework of categorical income taxation and construct a hierarchical identification mechanism based on economic substance. By leveraging data-intelligence-driven sharing of tax-related information and multi-party collaborative governance, tax authorities can achieve a paradigm shift in precision supervision, piercing the veil of transactional appearance to capture the essence of revenue, and thereby enhancing the overall efficacy of tax governance.