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永续债是一种没有规定到期期限的无期债券,发行方只需支付利息而不必偿还本金,由于永续债常被认定为权益工具,债券利息是否可以税前扣除的问题目前存在较大的争议。本文通过对国内外税收规定的比较和分析,对目前永续债税务处理存在的问题进行剖析,并提供了政策建议。
Perpetual debt is a kind of indebted bond which does not stipulate the expiration date, the issuer only needs to pay the interest without having to repay the principal. Since the perpetual bond is often regarded as the equity instrument, whether the interest of the bond can be deducted before tax is more than that Big controversy. Through the comparison and analysis of tax regulations at home and abroad, this paper analyzes the existing problems in the tax treatment of perpetual debt and provides policy suggestions.