混合性投资业务是指兼具权益性投资和债权性投资双重特征的投资业务,鉴于混合性投资业务作为企业一项创新投资业务,已被许多企业大量运用。尤其是信托公司,开展此类投资业务甚多。对这些问题,《企业所得税法》没有清晰的规定,存在各方理解和认识角度不同,出现各地政策执行口径不一。因此,迫切需要研究、制定相关税收政策为之配套。根据当前税收实际征管需要, The hybrid investment business refers to the investment business that combines the dual characteristics of equity investment and debt investment. Given that the hybrid investment business is an innovative investment business, it has been widely used by many enterprises. In particular, trust companies, to carry out such a large investment business. For these problems, the “Enterprise Income Tax Law” does not have a clear stipulation, and there are different understandings and understandings from different sides. There are different levels of policy implementation in various places. Therefore, there is an urgent need to study and formulate relevant tax policies. According to the actual tax collection and management needs,