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私募基金按照业务可以分成私募股权基金和私募证券基金。按照组织形式来区分,可以分成合伙型基金、公司型基金和契约型基金。按照交易主体来划分,它包括管理人、投资人、托管人等。结合公司的经营业务和交易类型等实际情况,本文主要解决私募股权投资基金从成立、运营到清算全生命周期的相关税务筹划问题。本文分为两大部分:第一部分以税种为主线,分别从基金、基金管理人和基金投资者三个层面对增值税、所得税、印花税的税务问题依次进行详细介绍;第二部分以案例的形式分别对有限合伙型基金、公司型基金和契约型基金的各交易主体涉及到的纳税环节、税种及计算方法进行详细阐述。
Private equity funds in accordance with the business can be divided into private equity funds and private equity funds. In accordance with the organizational form to distinguish, can be divided into partnership funds, corporate funds and contractual funds. Divided according to the main transaction, which includes managers, investors, trustees and so on. Combined with the actual situation of the company’s business operations and transaction types, this article mainly solves the tax planning issues related to the entire life cycle of a private equity investment fund from the establishment and operation to the liquidation. This article is divided into two parts: The first part is based on the tax type, the tax issues of value-added tax, income tax and stamp duty are described in detail from the fund, fund managers and fund investors respectively. The second part is a case study The paper elaborates on the tax payment sections, tax categories and calculation methods involved in the transactions of limited partnership funds, corporate funds and contractual funds respectively.