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英国essay代写:Group taxation in Britain and Spain

2019-05-14 | 来源:51due教员组 | 类别:Essay代写范文

本篇essay代写- Group taxation in Britain and Spain讨论了英国、西班牙集团的课税制度。在英国税制中,依据母公司直接或间接拥有子公司或其他公司票面股本的不同比率,英国集团公司可分为“50%集团”、“75%集团”、“90%集团”。英国合并纳税的企业集团以及成员企业是指国内母公司与由其控股比例达到75%或者51%以上的国内居民公司。西班牙税制中,只要母公司占有子公司的多数投票权,有权任命或解雇多数董事,能够与其他参股者达成的协议控制多数投票权就可以认定为在会计核算方面存在集团。本篇essay代写51due代写平台整理,供大家参考阅读。

Group taxation,课税制度,essay代写,代写,paper代写

Enterprise group is one or several large enterprises as the core, with capital goods, technology, etc. As a connecting link, by holding, equity and contractual relationship, by multiple has economic benefit of enterprise unit together, multi-level, many corporate economic union, enterprise group is one of the advanced organizational form of modern enterprise. The emergence of enterprise groups has brought many new problems to China's current income tax policy, such as how to determine the taxpayer, how to adjust the difference in taxable time, and how to implement relevant tax inspection. At the same time, there are some unfavorable factors in the current income tax policy. In order to meet the needs of marketization reform, it is imperative to perfect the tax reform of China's enterprise groups.

In the British tax system, British group companies can be divided into "50% group", "75% group" and "90% group" according to the different ratios of the par equity of subsidiaries or other companies owned by the parent company directly or indirectly. The enterprise groups and member enterprises that pay tax on the merger of the UK refer to the domestic resident companies with 75% or 51% of the shares held by the domestic parent company. In the Spanish tax system, as long as the parent company holds the majority voting rights of subsidiaries and has the right to appoint or dismiss a majority of directors, it can be recognized as the existence of a group in terms of accounting as long as it can reach an agreement with other shareholders to control the majority voting rights.

In the UK, a group or consortium may receive a group tax break if it is established through a company domiciled in the European Union or the European economic area. In Spain admitted domestic group under the condition of tax breaks, as long as the standing body of the head office in Spain does not belong to the residents of the subsidiary companies of Spain, signed in Spain and contains the terms of the exchange of information tax treaty country residence and subsidiary company belongs to the residents, the tax rate are the same as the holding company, can be regarded as holding company enjoy tax breaks.

75 per cent of UK corporate groups can transfer tax losses to another member, or a company that owns a consortium can transfer losses to other members of the consortium, and vice versa. In Spain, the holding company must directly or indirectly own more than 75% of the resident companies of non-independent companies within one year before filing the merger tax application and the remaining tax payment period. The holding company is not subject to the asset holding system.

UK: 75% of related companies can enjoy capital gains tax exemption for business transfer. Spain: the capital gains obtained from the sale of the shares of resident companies held prior to the transfer shall be tax-deductible if the total amount of the shares of resident companies held prior to the transfer exceeds 5% and the investors hold the shares continuously during the year prior to the sale.

The UK must separately calculate the operating loss and the asset loss, and the loss of the tax subject to the group offset tax exemption system is also the operating loss. Spain: the losses incurred by the companies prior to the merger period can only be written off against the profits of the same company. Losses incurred during the consolidation period shall be treated as normal losses.

Although China's existing enterprise groups have reached a certain number, but so far in China, the implementation of the consolidated tax system of enterprise groups is still only about 120. In contrast, in Britain and Spain, the enterprise groups and member enterprises that are allowed to merge and pay taxes refer to the domestic parent company and the domestic resident subsidiaries whose shareholding ratio reaches 75% or 51%. Therefore, in order to maintain the tax fairness between Chinese enterprise groups and improve their international competitiveness, China should try to expand the scope of applicable consolidated tax enterprise groups.

The tax reduction and exemption system for enterprise groups in China can only be applied to the consolidated tax payment system with the approval of the state administration of taxation. In Britain and Spain the rules are much looser. A group or consortium, for example, can get a tax break if it is set up by a company with a home in the European Union or the European economic area. As we all know, tax is not only the main tool to obtain fiscal revenue, but also an effective means to improve the international competitiveness of domestic enterprises. In our country modernization needs to introduce the foreign capital vigorously today, our country should widen the enterprise scope which includes the group tax reduction enterprise, enhances the domestic tax competition ability.

The current Chinese consolidated tax system only stipulates wholly-owned subsidiaries as the member enterprises within the scope of consolidated tax payment, and many holding subsidiaries are excluded from the national scope of the consolidated tax system. The same applies to group tax breaks, which are limited to wholly owned subsidiaries. This greatly restricts the combination of tax, tax relief system to promote the competitiveness of China's enterprise groups. In contrast, in Britain and Spain, the group tax deduction can be applied for between the consortium companies and the companies that have group relations with the members of the consortium. Therefore, in order to improve the competitiveness of Chinese enterprise groups, our country should also consider expanding the conditions of enterprise group merger tax payment and tax relief.

According to the statistics of the ministry of commerce, by the end of 2011, Chinese enterprises had established 18,000 overseas non-financial enterprises, with an investment of 424.78 billion us dollars. However, as the current system has not clearly defined the internal transactions of enterprise groups, it is difficult for tax authorities to curb the loss of tax revenue caused by internal transactions among enterprise group members. Although it is an incentive tax system to implement consolidated tax payment or tax reduction and exemption for enterprise groups, we should also impose necessary restrictions on intra-group transactions in terms of the specific design of the system. In the future, preferential tax policies should be more inclined to industrial preferential policies and adopt more effective methods such as accelerated depreciation.

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