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为满足特殊性税务处理的条件,企业需确保交易具备合理的商业目的,满足相关持股比例要求,并充分考虑预提所得税率的变化。随着经济全球化的发展,以及中国企业积极实施“走出去”战略,以跨境资本配置为目的的跨境并购重组日渐增多。与此同时,近年来国家税务总局针对跨境并购重组的企业所得税及相关流转税,陆续出台了一系列税收优惠政策,为企业实现递延纳税的税务筹划提供了空间。但这些税收
In order to meet the special conditions of tax treatment, enterprises need to ensure that the transaction has a reasonable commercial purpose, meet the relevant shareholding ratio requirements, and give full consideration to changes in withholding income tax rates. With the development of economic globalization and the active implementation of the “going out” strategy by Chinese enterprises, cross-border mergers and acquisitions and restructurings aimed at cross-border capital allocation have been increasing. In the meantime, in recent years, the State Administration of Taxation has issued a series of tax preferential policies for the corporate income tax and related turnover tax of cross-border mergers and acquisitions and reorganization, which provides room for enterprises to implement tax planning for deferred tax payment. But these taxes