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近年来,随着我国金融工具交易和金融产品创新快速发展,在金融市场中涌现出大量金融创新工具,这些金融工具既具有传统业务特征,同时又有别于传统业务,比如“混合投资”兼具股权与债权的基本属性,很难将其归属于某一具体的类别,对当前以股权与债权的区分为基础的二元制资本市场课税规则提出了严峻的挑战。现行税法就这些问题,没有清晰规定。因理解和认识角度不同,各个企业执行政策不一,也不乏有企业钻国家政策的漏洞。
In recent years, with the rapid development of financial instrument trade and financial product innovation in our country, a large number of financial innovation tools have emerged in financial markets. These financial instruments not only have traditional business characteristics but also different from traditional businesses such as “hybrid investment ”With the basic attributes of equity and debt, it is difficult to attribute it to a specific category. This poses a severe challenge to the current dual-system capital market taxation rules based on the division of equity and claims. The current tax law on these issues, there is no clear rule. Due to different understandings and understandings, various enterprises have different implementation policies and there are also some loopholes in the national policy of enterprises.