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在市场经济体制下,谋求最轻税负已成为纳税人孜孜以求的目标。对企业而言,税收筹划如果合理合法,则有利于减轻企业税负,增加利润和可用资金,促进企业的持续发展。税收筹划如果无法律依据,为筹划而筹划,则有可能导致征纳双方各执一词,筹划方案前功尽弃。以房地产行业为例,目前与房地产公司相关的税收筹划方案多如牛毛,但有些筹划所依据的相关法规是原则导向的,缺少执行的具体标准;有些则是从不同的角度来解读法规,相关法规的表述不明确,征纳双方对同一事件有截然不同的理解。鉴于此,“纳税&筹划”从本期开始将刊登朱光磊和王旭光的一组关于房地产公司税收筹划的系列案例,内容涉及营业税、土地增值税、企业所得税等相关税收争议问题,希望通过对这些颇具争议问题的解析,引发读者的思考与探讨。
Under the market economy system, the quest for the lightest tax burden has become the target pursued by taxpayers. For enterprises, if tax planning is reasonable and lawful, it will help to reduce the tax burden on enterprises, increase profits and available funds, and promote the sustainable development of enterprises. Tax planning if there is no legal basis for the planning and planning, it may lead to both parties to impose their own terms, planning programs come to naught. Take the real estate industry as an example. At present, there are many tax planning solutions related to real estate companies. However, some laws and regulations on which planning is based are principle-oriented and lack specific standards for implementation. Some of them also interpret laws and regulations from different perspectives. The expression is not clear, and both parties have a completely different understanding of the same incident. In view of this, “Tax & Planning ” from the beginning of this issue will be published Zhu Guanglei and Wang Xuguang a series of real estate company tax planning case series, involving business tax, land value-added tax, corporate income tax and other related tax dispute issues, The analysis of these controversial issues, triggering the reader’s thinking and discussion.