"Tax Planning Collection" reasonable set up institutions to enjoy the minimum tax rate

The state gives certain areas a certain tax preferential policy, not for no purpose, but to encourage the development of certain types of enterprises in these areas, and to enjoy these preferential tax policies are mainly operating longer, larger investment of productive enterprises.

It is worth noting that the impact of tax incentives in a given region is by no means confined to the taxpayers in the region, and that taxpayers in the region may also use these preferential tax policies for legal tax planning to mitigate the tax burden.

A multinational company in Shenzhen and Hebei province in a county, respectively invested in the establishment of two foreign-invested enterprises S and P company, both companies to produce the same mechanical and electrical products.

S company is responsible for the new electromechanical products research, development, and responsible for production, sales;

P Company is only responsible for the production and sales in the region.

1998, S company because of its development and production of mechanical and electrical products advanced technology, high production efficiency, good sales status, research and development costs and other indicators are standard, by the Shenzhen Science and Technology department identified as high-tech enterprises. In 1998, s company achieved sales revenue of more than 90 million yuan, after-tax profit of 15 million yuan. P company to achieve sales revenue of more than 45 million yuan, and after-tax profit only 4 million yuan. S company, p company in the management model, material costs are not materially different; in labor costs, p company is lower than S company, but P company's profit is significantly less than S company.

For this reason, the multinational company commissioned a tax consultant to analyze the financial and tax situation of P Corporation.

After accepting the Commission, the tax consultant compared the situation of S and p two companies, and found the following situation:

First, s company has begun to profit in 1998, by application and was recognized as "high-tech enterprises", enjoy the special economic zone on high-tech enterprises preferential policy: where is recognized as a high-tech enterprise, corporate income tax enjoy " two free three halves " preferential policies. According to this policy, s company carries out 7.5% of the income tax rate from 2000 ~2002 year.
Second, the company's production materials in addition to duty-free imports , its domestic suppliers are mainly located along the Yangtze River, procurement prices are the same; both companies have roughly equal material consumption of the same electromechanical products.
Third, the company was established in 1997, 1997, 19,982 years after two years of tax exemption, began to pay 15% of the tax rate of enterprise income tax, three years after its corporate income tax rate will be 30% (excluding the local part).
By comparison, how to combine the strategic planning of the company with the preferential tax policy of the enterprise is the key to the tax planning.

According to the provisions of the relevant tax law, S, p two companies in the preferential income tax policy has a greater difference:

S company can enjoy 15% preferential tax rate, you can enjoy the "two free three discount" preferential period policy, if the tax exemption expires after still belong to advanced technology enterprises, can be in accordance with the tax law to extend the rate of three years in half levy enterprise income tax, the tax rate is generally 10%;

P Company can enjoy the "two free three minus" preferential policy, but the tax rate is 30% (the above tax rate does not include the local part).

Based on S company, p companies enjoy the different tax preferential policies, tax planning recommendations are as follows:

The original P company production of products by S company production, s company can be certain production process by P company, the procurement of raw materials by s company to complete.

P company equivalent to s company's processing plant, not responsible for the final product sales, in the financial response to accept commissioned processing business , by S company responsible for the sale of all self-produced products. The results of the above tax planning implementation are as follows:
S, p two companies all the value of the company reflected in S company, the original P company's product sales business by S company, by S company in its location in Shenzhen to pay corporate income tax.

S company to the P company issued a commission processing single, should settle commissioned processing fee,p Company's income is mainly embodied in the entrusted processing fee income .

"Tax Planning Collection" reasonable set up institutions to enjoy the minimum tax rate