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交易价格是否公允常引发税企争议,税务机关常借助资产评估结论来加以审核和调整。本文提出,运用资产评估结论时应当注意:资产评估结论是基于资产自身属性的价值反映;会计、税法中的公允价值是在资产价值基础上加以市场因素调整的交易结果 ;资产评估虽然遵循税法却无法顾及个体化的税收政策,从而形成不同于税法口径的评估结论。此外,借助资产评估结论,能够合理解决一揽子交易的价格分摊问题,有效降低涉税风险。
Whether the transaction price is fair or not often leads to tax disputes, tax authorities often rely on assets assessment conclusions to be reviewed and adjusted. This paper proposes that the conclusion of asset evaluation should be taken into consideration: the conclusion of asset evaluation is the value reflection based on the property of the asset; the fair value of accounting and tax law is the result of the transaction adjusted by market factors on the basis of asset value; Unable to take into account the individual tax policy, thus forming a different assessment of the tax law conclusions. In addition, with the help of asset valuation conclusion, the issue of price allocation of a package of trades can be reasonably solved and the tax-related risks can be effectively reduced.