Clever Choice Of Tax Plan For Different Uses Of Financial Funds

A company is a wholly state-owned enterprise, engaged in highway passenger pport business, its subordinate passenger west station, east station, passenger pport branch and repair plant.

In April 2013, according to the summary of the special session of the people's Government of the A Municipality on the construction of the Western pportation hub project, the passenger terminal will be relocated to the new West pportation hub according to the urban planning layout for the high-end commercial complex project.

The source of construction funds is 800 million yuan from bank a to the bank, with a period of 2 years, an annual interest rate of 7.2%, and quarterly interest payments.

The principal repayment time is 2015-2016, and the annual repayment is 400 million yuan.

The project started construction in July 1, 2013 and was delivered in July 1, 2015.

In July 20, 2015, the A Municipal People's government made a principled arrangement on the revenue of the West Railway Station in respect of the conference on the demolition of the comprehensive land mass at the West Railway Station (forty-eighth issue): the land department calculated the land pfer proceeds according to the price of the land sold by the Ministry of land, and after deducting the above provincial regulations, it was about 500 million yuan. As a construction fund for the Western passenger pport hub, it is expected to be in place in December 2015, and the gap of 300 million yuan will be solved by the municipal government as a whole.

Due to the departure of the Western passenger terminal from the urban area, the number of buses is small, which affects the travel of passengers.

A company has been operating for 1 months, and its average daily operating income has decreased by 80 thousand yuan, and its revenue in 2015 is expected to decline by 14 million yuan compared with the same period last year.

As of July 31, 2015, a company's accounting account reflects the net home value of the passenger terminal 31 million 790 thousand yuan.

The net value of the right to the use of land is 25 million 960 thousand yuan.

The cost of long-term deferred expenses reflects 2 million 250 thousand yuan for decoration and a total of 60 million yuan.

A company is bidding for the society, demolishing the houses, buildings and attachments at the West passenger station. The net income of the demolition is 2 million yuan.

The net loss of the disposal of assets was =6000-200=5800 (ten thousand yuan).

I. Analysis

Based on the above information, a company entrusts tax officers from the perspective of tax risk and cash flow to analyze the relocation of passenger pport west station and the problems faced by western hub construction funds, so as to provide basis for decision-making.

The tax division believes that the relocation of policy to the company has the following adverse effects: decrease in operating income, interest on new loans and depreciation of fixed assets, and disposal of net assets losses.

These factors will reduce profits; in 2015, the principal and interest of the loan should be repaid 457 million 600 thousand yuan and the repayment pressure will be great.

The 48 phase of the meeting of the municipal government only used the net income of the West passenger terminal for the Western passenger pport hub project. Why not?

The financial manager explained that enterprises are consulting with relevant government departments. The feedback is that the total amount of financial resources will not change, and the purpose can be discussed.

After discussing with the financial manager, there are three tax plans for different purposes.

Two, scheme and comparison

(1) all policy moves.

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The announcement of the State Administration of Taxation on Issuing the administrative measures for the enterprise's policy relocation of income tax (No. fortieth of the State Administration of Taxation announcement 2012).

The relocation income of the enterprise includes the relocation compensation income obtained from the enterprise (including the government or other units) in the process of relocation, as well as the disposal income of the enterprise's relocation assets.

The relocation expenses of enterprises include relocation expenses and the disposal expenses of enterprise assets due to relocation.

The assets purchased by an enterprise shall not be deducted from the relocation income.

The relocation income of enterprises, after deducting the balance after relocation expenses, is for the relocation of enterprises.

A company's policy relocation compensation income is 500 million yuan, the fixed assets disposal income is 2 million yuan, the book assets net value is 60 million yuan, and the relocation cost is negligible.

The amount of income from policy relocation is =50 000+200-6 000=46 000 yuan.

The enterprise income tax shall be =46 000 x 25%=11 5 million yuan.

A company can actually use the financial capital =50 000-11 500=38 500 (10000 yuan).

In this way, there is no risk in tax operation, but the cash flow is reduced, which can not meet the demand for repayment of principal and interest of bank loans.

(two) all state-owned assets are invested into financial means.

Notice of the State Administration of Taxation on certain issues concerning the amount of taxable income of enterprise income tax (Bulletin No. twenty-ninth of the State Administration of Taxation 2014).

The people's governments at or above the county level, including government departments concerned, explicitly invest in state-owned assets by means of equity investment, and enterprises should be treated as state capital (including capital reserves).

A company obtains 500 million yuan invested by the government. It does not belong to taxable income, and does not need to pay corporate income tax. It increases the source of funds for repayment of loans.

The net loss of passenger pport west station is 5 800 yuan. Without any compensation, special tax declaration should be made to the competent tax authorities.

However, in the coming years, the tax authorities will find out that the relocation of the company will not be compensated for the relocation of the company, and it will be inappropriate for the company to carry out tax assessment and inspection.

(three) co-ordinate arrangements for different purposes.

The specific idea of operation is that the net revenue of the Western passenger station land listed by the financial arrangement is 500 million yuan. The government made clear the policy relocation compensation income of 60 million yuan in the document, and the SASAC invested 440 million yuan in a company.

In this way, the loss of policy relocation can be fully compensated, and the =6 000-5800=200 (10000 yuan) will be relocated.

There is no question of paying corporate income tax by investing 440 million yuan from the government.

It not only evaded tax risks, but also increased the cash flow of repayment loans to a certain extent.

In the three tax planning schemes, various factors that reduce the accounting profits are encountered in the construction of the Western passenger pport hub project.

But they are all objective facts and can be clearly stated to the competent tax authorities.

A company adopted the third plan put forward by the tax collector.