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许多国有独资企业为了更快更好地发展经济,通过股权无偿划转的方式进行资源整合,优化资本结构,从而达到提高企业效益的目的,但在股权无偿划转过程中所涉及的企业所得税问题上,企业管理者和会计人员都存在困惑,各地税务局对此项业务的政策也不明确。本文结合税收相关文件,提出了具体建议:国有独资企业股权无偿划转行为虽然是不同法人间的资产划转行为,但可以看作是同一主体内部的股东权益转移,是一种非市场行为,所以同一国有独资企业集团内全资母子公司或全资子公司之间的股权无偿划转,应暂缓交纳企业所得税,待此笔股权划出到集团外其他企业时,按转出价格确定收入或按市场公允价值核定收入计算交纳企业所得税。
In order to develop the economy faster and better, many state-owned enterprises achieve the objective of improving the efficiency of enterprises through the means of resource-free transfer by means of equity transfer and optimization of the capital structure. However, the issue of enterprise income tax On the business managers and accounting staff are confused, the local tax administration’s policy on this business is not clear. In this paper, tax-related documents, put forward specific recommendations: Although the transfer of equity stake in state-owned enterprises is a transfer of assets between different legal entities, but can be seen as the transfer of shareholder rights within the same subject is a non-market behavior, Therefore, the shares of the wholly-owned parent company or the wholly-owned subsidiary within the same state-owned enterprise group should be transferred freely and the enterprise income tax should be suspended. When this share equity is drawn to other enterprises outside the group, the income will be determined according to the transferred-out price or According to the market fair value of the approved income calculated by paying corporate income tax.