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问:在中国境内没有设立机构的外国租赁公司,以租货贸易方式,将设备、物件等租给中国境内用户使用,所收取的租赁费中包括设备、物件价款,应当如何计算缴纳所得税? 答:在我国境内没有设立机构的外国租赁公司,以租赁贸易方式,将设备、物件等租给我国境内用户使用,分期收取的租赁费中包括设备、物件价款,租赁期满后,设备、物件归用户所有(包括租赁期满后作价转让给用户)的,应报经当地税务机关审查核实后,从分期收取的租赁费(包括租赁期满后作价转让给用户的价款)中扣除设备、物件价款,以其余额为应纳税的租金所得,按照《中华人民共和国外国企业所得税法》第十一条的规定,由支付单位(即用户)扣缴20%的所得税。
Q: Foreign leasing companies that do not have an establishment in China rent their equipment and articles for use by users within the territory of China by means of rent and lease trade. The leasing fees charged include the price of equipment and articles, and how should income tax be calculated? : Foreign leasing companies that do not have an establishment in China use leasing trade to lease equipment and articles to users in our country. The leasing fees collected in installments include the price of equipment and articles. After the lease expires, the equipment and articles belong All users (including the lease after the expiry of the price transferred to the user), shall be submitted to the local tax authorities for examination and verification, the rental fee collected from the installments (including the lease after the expiry of the price transferred to the user’s price) deducted from the equipment, object price , With the remaining amount as the taxable rental income, a 20% income tax shall be withheld by the paying unit (that is, the user) according to Article 11 of the “Law of the People’s Republic of China on Income Tax of Foreign Enterprises”.