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根据各地在企业所得税执行过程中反映的情况,现将企业补贴收入等几个具体问题的执行口径统一明确如下:一、企业取得国家财政性补贴和其他补贴收入,除国务院、财政部和国家税务总局规定不计入损益者外,应一律并入实际收到该补贴收入年度的应纳税所得额.二、纳税人为其他独立纳税人提供与本身应纳税收入无关的贷款担保等,因被担保方还不清贷款而由该担保纳税人承担的本息等,不得在担保企业税前扣除.三、企业的一切工资性支出,包括企业列入管理费的各项补助等,在确定计税工资和挂钩工资时,应全部计入工资总额.四、投资方从联营企业分回利润,若投资方企业发生亏损的,应先用于弥补亏损,弥补亏损后有盈余的,应依照对联营企业补税的有关规定,按投资方企业法定税率与联营企业适用税率的差额计算补
According to the situation reflected in the implementation of the enterprise income tax system in various parts of the country, the specific implementation of several specific issues such as enterprise subsidy income is hereby unanimously defined as follows: 1. The enterprise obtains state financial subsidies and other subsidy incomes. Except for the State Council, the Ministry of Finance and the state tax The State Administration of Taxation shall not be included in the profits and losses, should be incorporated into the actual receipt of the subsidy income taxable income .In two, the taxpayer for other independent taxpayers and their own taxable income is not related to loan guarantees, etc., because the secured party Not knowing the loan and the principal and interest borne by the guaranteed taxpayer shall not be deducted before the guarantee enterprise tax.3.All wage and salary expenses of the enterprise, including various subsidies included in the management fee of the enterprise, Linked wages, should be included in the total amount of wages .In four, the investor points back from the joint venture profits, if the investment business losses, should be used to make up for losses, to make up for losses after the surplus, should be in accordance with the affiliated enterprises make up The relevant provisions of the tax, according to the difference between the statutory tax rate of the investor’s enterprise and the applicable tax rate of the joint venture