摘要： 当前，我国营改增试点扩围正在稳步推进之中。本次改革的动因主要是经济增速放缓倒逼税制改革，具有浓重的经济政策色彩。从法学角度分析，改革应当遵循分配正义的价值取向，并以推进财税法治作为保障。这不仅与其经济政策目标一致，且更符合当下国民收入分配制度改革的要求。本文从国家与纳税人之间、中央政府与地方政府之间及纳税人之间的关系入手，以分配正义价值考量营改增试点扩围及其整体税制改革的顶层设计之得失，通过探索财税法治的完善路径，以期既能确保实现其宏观调控的经济政策目标，又能在更深层面上理顺相关各方的利益分配关系，从而达致公平与效率的最大化。

关键词: 营改增试点, 国民收入, 分配正义, 财税法治

Abstract: The extension of the pilot BT reforms to VAT in China is going forward steadily at present. Since the main reason for it is the decline of economic growth rate, the reform is carried out primarily to promote economic boost. However, the reform should even more follow the value orientation of distributive justice and regard promoting the rule of law as a practical guarantee from the law angle, which has no conflict with the goal of promoting economic growth and is more accorded with the requirements of the reform of the national income distribution. On that account, this paper plans to sum up the gain and loss of the system design in the reform from an angle of distributive justice value included in the principle of tax fairness through analyzing the relationship between the state and taxpayers, the central government and local government and the taxpayers themselves. It then explores the way to improve the reform, hoping not only to ensure the economic goal of macro-control to be achieved, but also to coordinate the interests of the parties concerned and finally  achieve maximum benefit of fairness and efficiency on the whole.

Key words: BT to VAT Reforms, National Revenue, Distributive Justice, Rule of Law in Finance and Taxation