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2015年3月18日,国家税务总局发布《关于企业向境外关联方支付费用有关企业所得税问题的公告》(国家税务总局公告2015年第16号,以下简称“公告”),进一步规定企业向境外关联方支付费用的基本原则、管理要求以及税务机关追溯调整年限等相关问题。公告规定,企业向境外关联方支付费用应当符合独立交易原则,并按照税务机关的要求提供其与关联方签订的合同或协议,以及证明交易真实发生并符合独立交易原则的相关资料。公
On March 18, 2015, the State Administration of Taxation promulgated the “Notice on Enterprise Income Taxes for Enterprises’ Expenses Payed to Overseas Affiliates” (Announcement No.16 of 2015 by the State Administration of Taxation, hereinafter referred to as the “Notice”), further stipulating that enterprises The basic principle of paying fees to overseas related parties, management requirements and tax authorities retroactive adjustment period and other related issues. According to the announcement, an enterprise shall pay its own expenses to an overseas related party in accordance with the principle of independent transaction and provide it with the contract or agreement it has signed with its related parties as required by the tax authorities and relevant information proving that the transaction actually took place and complied with the principle of independent transaction. public