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最近,国家税务总局对依照涉外税收法律缴纳各项税收的股份制企业有关税收政策问题明确如下:一、资产重估变值的税务处理(一)外商投资企业改组,或者与其他企业合并成为股份制企业,原外商投资企业已在工商行政管理部门注销登记的,其资产转为认股投资的价值与其帐面价值的变动部分应计入原外商投资企业损益,计算缴纳企业所得税。(二)原外商投资企业已按上款规定做出税务处理的,新组成的股份制企业可以对原外商投资企业的资产,按重估确认的价值作为投资入帐,并据以计算资产的折旧或摊销;原外商投资企业未按上款规定进行税务处理的,对新组成的股份制企业中原外商投资企业的资产重估价值变动部
Recently, the State Administration of Taxation has clarified the relevant taxation policies on joint-stock enterprises that pay various kinds of taxes in accordance with the law on foreign-related tax revenue: 1. Tax Treatment of Variables with Revalued Assets 1. The reorganization of foreign-invested enterprises or the merger with other enterprises into joint-stock enterprises If the original foreign-invested enterprise has already been canceled and registered in the administrative department for industry and commerce, the part of the value of the assets transferred to the stock investment and the change of its book value shall be included in the profits and losses of the original foreign-invested enterprises and the enterprise income tax is calculated and paid accordingly. (2) If the original foreign-invested enterprise has already made a tax treatment according to the provisions of the preceding paragraph, the newly formed joint-stock enterprise may record the assets of the original foreign-invested enterprise on the basis of the revalued value as the investment and calculate the depreciation of the assets accordingly Or amortization; if the original foreign-invested enterprise fails to carry out tax treatment according to the provisions of the preceding paragraph, the revaluation of assets of the newly formed joint-stock enterprise Zhongyuan Foreign-invested Enterprise