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在社会主义市场经济条件下,税收筹划对企业经营虽然非常重要,但并不是任何税种、任何经营行为都可以筹划、都有必要筹划,不恰当的、违法的筹划反而会给企业造成损失。 A公司为一大型商业零售企业,其经营范围除包括自营家电、百货、农用生产资料外,还受托代销其他企业单位和个人的服装、鞋帽等商品。在1999年税收检查中,A公司就受托代销商品事项与税务机关发生纳税争议,并进行了税务行政复议。案件具体情况如下:
Under the conditions of a socialist market economy, although tax planning is very important to business operation, it is not a tax. Any business operation can be planned. It is necessary to plan. Inappropriate, illegal planning can actually cause losses to the enterprise. Company A is a large-scale commercial retail enterprise. Its business scope includes the sales of clothing, shoes and hats and other commodities of other enterprises and individuals in addition to self-operated household appliances, department stores and agricultural means of production. During the 1999 tax inspection, Company A paid a tax dispute with the tax authorities on the matters entrusted with consignment sales and conducted a tax administrative review. The specific circumstances of the case are as follows: