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按照现行税法规定,从事商品批发、调拨的纳税人,在商品销售后,以商品销售额减去销售商品购入原价后的差额(亦称进销差价),作为交纳批发营业税的计税依据。从几年来的实践情况看,以上计税依据,往往在企业之间造成明显的税负不均问题:(1) 同一种商品由于进货地点不同而税负不同。一般来讲,产销两地的距离越远,地区差价越大,企业支出的运输费用也就越多,如果仅仅依靠进销差价来计征营业税,企业支出的运输费用就难以得到足额补偿。造成差价越大,税负越重;差价越小,税负越轻。(2) 有些盈利水平本来相近的商品,但由于按进销差价计征营业税,导致最终经营成本相差悬殊。例如有的商品体积大,价值小,进货费用高,企业为补偿较高的进货费用,其毛利率相应定得高些;有的商品体积小,价值大,支付的进货费用少,毛利率就相应定得低些。较高的毛利率负担较高的进货费用,较低的毛利率负担较低的进货费用,两者的盈利水平本应相对接近,但在计缴批发营业税以后,往往毛利率低的商品的盈利水平高于毛利率高的商品。(3) 由于对减免税照顾政策的掌握宽严有
In accordance with current tax laws, taxpayers engaged in the wholesale and transfer of goods shall, after the sale of goods, use the difference between the sale of goods less the original price of the sale of the purchased goods (also known as the difference between the selling price and the selling price) as the tax basis for the payment of the wholesale business tax. Judging from the practice in recent years, the above taxation basis often results in obvious problems of inequality of taxes among enterprises: (1) The same goods have different tax burdens due to different locations. In general, the farther the distance between production and sales, the greater the regional spread, the more the cost of transportation of business expenditures. If only relying on the difference between the sales and sales to collect business tax, it will be difficult to obtain full compensation for transportation expenses incurred by enterprises. The larger the difference, the heavier the tax burden; the smaller the difference, the lighter the tax burden. (2) Some goods with similar profitability levels, but due to the collection of sales tax based on the difference between the sales and purchase price, the final operating costs are very different. For example, some products are bulky, of low value, and have high purchase costs. The company’s gross margin is set to be higher in order to compensate for the higher purchase cost; some products are small in size, have large value, and the purchase cost paid is small, and the gross profit rate is small. Correspondingly set lower. Higher gross margins burden higher purchase costs, lower gross margins take up lower purchase costs, and the profit level of the two should be relatively close, but after paying the wholesale business tax, the profit of the goods with low gross profit margin is often higher. The level is higher than the commodity with high gross margin. (3) Due to the strict control of the tax relief policy