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一,支付境外非居民利息税款的计算与扣缴(一)支付境外非居民利息流转税的税收规定根据《中华人民共和国营业税暂行条例》及其实施细则的规定,在中华人民共和国境内提供条例规定的劳务、转让无形资产或者销售不动产的单位和个人,为营业税的纳税人,应当依照本条例缴纳营业税。境内是指提供或者接受条例规定劳务的单位或者个人在境内。在向中国境外的非居民借款活动中,虽然贷款人在境外,但借款人在境内,按照上述规定,贷款人发生了纳税义务,应当计算缴纳营业税。(二)支付境外非居民利息预提所得税的税收规定1.预提所得税的源泉扣缴。根据《非居民企业所得税源泉扣缴管理暂行办法》(国税发[2009]3号)第三条规定,对中国境内未设立机构、场所的非居民企业取得来源于中国境内的股息、红利等权益性投资收益和利息、
I. Calculation and Withholding of Taxes on Interests Payed by Overseas Non-residents (I) Tax Regulations on Payment of Turnover Taxes on Interests of Overseas Non-residents According to the Provisional Regulations of Business Tax of the People’s Republic of China and its Implementing Rules, the tax regulations of the People’s Republic of China Stipulated labor services, transfer of intangible assets or units and individuals that sell immovable property, the taxpayers who are business tax shall pay business tax in accordance with these Regulations. Domestic refers to the provision or acceptance of services provided by the Ordinance units or individuals in the territory. In lending to non-residents outside of China, although the lender is outside the country, the borrower is in the country according to the above provisions, and the lender has a tax liability and should calculate and pay the sales tax. (B) to pay the non-resident foreign interest income withholding income tax provisions 1. Withholding income tax withholding. According to Article 3 of Interim Measures on Withholding of Sources of Corporate Income Tax of Non-resident (Guo Shui Fa [2009] No.3), the Company obtained rights and interests such as dividends and bonuses originating in the territory of China from non-resident enterprises that have no establishment or place in China Sex investment income and interest,