论文部分内容阅读
一、关于投资总额、注册资本与资本利息的问题。资本利息不得列支,这一规定已明确写进了我国中外合资企业所得税法和外国企业所得税法的实施细则中。但在实践中,我们执行这一规定有很大的困难。按照我国现行涉外法规的有关规定,资本(或称注册资本)是按照企业投资总额的一定比率确定,并经国家工商行政管理部门在其签发的工商营业执照中予以确认。但由于客观(如汇率变动)或主观(如可行性研究的差误)方面的原因,外商投资企业合同中规定的投资总额与实际发生的投资总额并不都是一致的,有的差异很大。有些管理外商投资企业的政府主管部门(如外经贸委、工商
First, on the total investment, registered capital and interest on the issue of capital. The interest of capital can not be disbursed, this provision has been clearly written into the implementation details of the Income Tax Law of Sino-foreign Equity Joint Ventures and the Foreign Enterprise Income Tax Law. However, in practice, we have great difficulties in implementing this provision. According to the relevant provisions of the current foreign laws and regulations of our country, the capital (or registered capital) is determined according to a certain ratio of the total investment of the enterprise and confirmed by the state administration for industry and commerce in the business license issued by it. However, due to the objective (such as exchange rate changes) or subjective (such as the feasibility study of the error) reasons, the total investment in the contract of foreign-invested enterprises and the actual total investment is not always the same, some very different. Some government departments in charge of foreign-invested enterprises (such as the Foreign Trade and Economic Cooperation Commission, the Ministry of Industry and Commerce