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随着外商投资企业的不断增加和发展,近几年,外商承包经营企业也迅速增加。在对外商承包经营企业计征所得税时,对承包费能否作为承包企业生产经营费用在税前列支问题,我谈点看法。一、承包经营企业的纳税人问题由于承包经营企业形式多样,情况错综复杂,我们在征税时,有必要首先搞清不同形式承包企业的纳税人问题,然后再探讨承包费的财务处理问题。承包经营企业情况不同:(1)承包者不同,既有外商,也有内商;既有企业,也有个人。(2)被承包企业不同,既有外商投资企业,
With the continuous increase and development of foreign-invested enterprises, the number of foreign-funded contract-operated enterprises has also increased rapidly in recent years. When assessing income tax on foreign contractual joint ventures, I would like to comment on whether the contracting fees can be used as a pre-tax support for contracting enterprises’ production and operating expenses. First, the problem of taxpayers contracting business As a result of various forms of contracting business enterprises, the situation is complicated, we are taxing, it is necessary to first find out the taxpayers in different forms of contracting enterprises, and then explore the financial problems of contracting fees. Contractors are different: (1) different contractors, both foreign and domestic business; existing enterprises, as well as individuals. (2) Different from contracting enterprises, both foreign-invested enterprises,