税收-外文翻译-外文文献-英文文献-企业税收筹划的主要途径
企业增值税纳税筹划外文文献翻译最新
外文文献翻译:原文+译文原文The research of corporate V AT planningPhillips J DAbstractEnterprise tax planning is very necessity. But most tax planning of enterprise is so difficult, the manager normally feel do not know how to start it. This is mainly because when doing tax planning personnel breadth and depth of thinking is limited. In fact, in view of the enterprise a certain business, as long as the tax personnel to all business related tax law research understand the relevant rules and regulations are in place, so companies when doing tax planning should be no problem. For example and to increase "camp" the tax planning, the categories of taxes that must be considered including the business tax and value-added tax, the relevant expenses such as urban maintenance and construction tax and educational expenses to add. Of course, the enterprise can not only consider when do tax planning; a business enterprise's business is very broad, so when doing tax planning to overall consideration. Keywords: value-added tax; the individual income tax; Tax rate; Tax planning1 IntroductionEnterprises between the increasingly fierce markets competitions, enterprises want to gain share in the market, a place, you must adapt to the evolution of natural law, has the stronger than other enterprise competitive power, and this kind of competition power depend mainly on market segment and reduce the cost. Undoubtedly tax is an important part in enterprise cost, the main body of enterprise tax include value added tax, income tax, business tax, consumption tax, etc., and occupy the largest proportion of is value added tax, accounting earnings and the realization of the goal of the enterprise plays an important significance. Because different countries have different social and economic development to its policy orientation, so differences exist in different countries and different industries, the tax policy and accounting system for the choice of accounting methods more flexible, which provides a choice of V AT tax conditions and space? The V AT tax planning forenterprise attention, recognition and more and more attention. Tax planning in gradually improve, already have a systematic and market characteristics. And the development of society, market economy unceasing prosperity, has prompted the company constantly innovate oneself production mode, operation concept, management style, etc.For the survival and development to adapt to market competition, enterprises will use every possible method to increase the interest, as far as possible to reduce the amount of unnecessary consumption, so how to reduce the tax burden is the problem that managers must consider carefully. Modern enterprises in pursuit of the enterprise value maximization as the goal development relative to evade taxes and tax risk of higher taxes, so business leaders can choose to reduce the tax, tax planning the implementation of reasonable overall planning can make the company a huge income.2 V AT descriptionsValue-added tax is the enterprise product in the process of production, circulation, and the value added part of the labor service or value added, the additional levy taxes. No matter which country, regardless of its power, as long as it is a value-added tax, to enact specific regulations on value-added tax. Generally divided into three kinds, one is the production, the second is income-producing, and three is a consumer.2.1 Production-type V ATProduction-oriented V AT has relationship with the company's production, it is well known that a mature enterprise need fixed plant, equipment, products used in the production of raw materials, transportation, fuel, fixed assets, product sales and production of profit, the sales revenue minus the production and operation of the balance of the raw materials, fuel and power as prescribed by the state of appreciation, this also is the basis of the production V AT, in principle, value added tax is not to be bought and depreciation of fixed assets, value added tax is a period of time limit, the tax basis by the tax unit labor balance, and used in the production of loss and the balance of sales revenue, which belongs to the category of value-added tax, fixed assets depreciation is used in the process of transfer value, is also a part of value-added tax levy, which is called double taxation. Based on this, with a largeenterprise as an example, the higher its value of fixed assets, to the payment of taxes, the more because of the wear and depreciation is not deducted, in the process of production is also repeat pay; This part of income is almost equivalent to the gross national product, so called the production-oriented V AT, it includes the rent, wages, profits, interest and depreciation of fixed assets, etc.2.2 Consumption-type V ATIn a word, it is not including the current depreciation of fixed assets and net income tax, including the taxpayers' wages, profits, interest, and rent, etc., in terms of a country, relative to the production-oriented V AT is gross national product, net national product. It is deducted for the production of all the value of fixed assets and depreciation forehead, purchased raw materials and labor value of net income, after is the income of the enterprise production and sales, including spending part, such as wages, so called income-producing V AT.2.2 Income-type V ATDue to the use of standard, advanced, has a legal basis, is engaged in the tax accounting practical operation is simple, popular among countries in the world. A category is a one-off deducted for production and operation of the fixed assets value and the value of the purchase raw materials in the tax, that is to say, the taxpayer’s tax products for production and operation, and are not all the outsourcing material to this category. Fixed assets has been imposed production V AT, of course, but the operator is used as a purchase of fixed assets, its tax gold when the purchase has been deducted, relatively, this part of the goods as fixed assets, there would be no tax, as the nature of the V AT collection does not include other production of raw materials, only including the management of all sales of consumer goods. Consumer is a use of special V AT invoices for V AT tax withholding of taxes, occupies a certain advantage, due to its treatment scope strictly enforced, standard, has certain advancement, and are applicable in many countries.3 The characteristics of added-value tax3.1 Wide taxEnterprise engaged in the work of production and sales for the main V ATcollection objects, individuals engaged in business also in the collection and processing, such as small restaurants, small articles of daily use operators, etc., are widely applicable to all kinds of ownership enterprises and individuals, embodies the fairness of the tax system.3.2 Indirect taxV AT calculation is not directly to value multiplied by the applicable tax rate to calculate the tax payable, but by buried output tax and tax balance to determine the tax payable. Although V AT is the value-added tax on appreciation forehead that increases the value or goods, but in the actual execution process, due to the added value of goods or services or goods value is a difficult to calculate the data, so the V AT only by way of indirect tax. Indirect tax measures increased the difficulty of the value-added tax calculation and collection management.3.3 Additional taxGoods have to be sold by pricing, V AT tax refers to the outside valence is not including commodity tax on the original price. When selling goods, should will receive all the money was divided into excluding V AT price sales and value added tax, and on the special V AT invoices to the tomb-sweeping day, respectively, in this way, the V AT on revenues, costs and profits will not occur, also need not collect V AT included in the income statement. Although it is important to note that the V AT is outside valence tax, but the sales direction while receiving payment from buyers tend to be merged charge, through a certain calculation formula of a sales tax were decomposed into will not sales tax and value-added tax, and fill in the V AT special invoice respectively, rather than in the place where has to determine the price of the total sales of value-added tax calculated separately again.3.4 Special invoiceV AT is absolute and levy, in order to avoid only partially and the phenomenon of double taxation, must carry on the effective control of each link, implement V AT is unified, special invoices, and according to the stated on the invoice amount to impose a tax deduction method, this is the main method for effective control. Countries introduced related management way, strengthen the management of the specialinvoice, the rules on the scope of the use of special V AT invoices, the invoice issued the purpose to make clear a regulation, also completed, enterprises have an obligation to give the buyer special invoices for value-added tax, and to do specialized tickets, taxable services shall be paid not, except duty-free goods also. All invoices shall be protected by law. Special invoices for specific use measures enterprises in strict accordance with the provisions of the calculation, on the basis of the in and out of balance of the current period by the enterprise, both reasonable and legitimate, is the duty of the taxpayer. Thus, to strengthen the taxpayer over the use of special V AT invoices highlighted the value-added tax levy management effect.4 The V AT tax planningV AT tax planning is the content of the enterprise according to their own economic activities, on the premise of not illegal, V AT tax matters to the enterprise to seek planning V AT tax minimization of planning and arrangement. It has the following features:4.1The result of V AT tax planningCity building duty and educational expenses to add belongs to attach tax, as the value-added tax falls. But at the same time, if the two tax drops, can lead to enterprise's total profits, so the enterprise income tax will rise. So, the result of the tax planning may be related to some deviation from the ultimate goal of enterprises to reduce tax burden.4.2 V AT special invoices for value-added tax planningInvoice buckle tax law is a common way to calculate the V AT payable taxes, so special invoices for value-added tax management is the key content of value added tax management. Enterprise product sales directly affected by the special invoices for value-added tax, can open will promote the further development of the enterprise; on the other hand, will affect the size of the enterprise. So, V AT tax planning is the need of the development of the enterprise, therefore in the process of V AT tax planning, to consider the problem of special V AT invoices to the enterprise development prospects.4.3 The planning of the tax burden onKnown to value added tax is a turnover tax, also proves that it is the identity ofthe indirect tax, from the nature of the object defined, flow from it this is the flow of goods, the circulation tax included in commodity prices, determines the turnover does not open automatically. And tax excluded in price, taxes are independent in accounting book, looks like has nothing to do with the price, but it is also part of the purchase price, income tax is directly understand hang, V AT tax on hidden is indirectly. Because of V AT qualitative, its scope covers almost all walks of life, can say all the goods in the column, but for taxpayers, because taxes will rise in price is not reasonable publicly, will be opposed by the consumers. So, the taxpayer can only secretly push up commodity prices, will tax include in the price, do not attract the attention of consumers, easy will be passed on to the purchaser, tax and consumers don't know, so don't oppose.文献出处：Phillips J D. The research of corporate V AT planning [J]. The Accounting Review, 2016, 1(3): 40-52.译文企业增值税纳税筹划研究Phillips J D摘要企业进行纳税筹划是非常有必要性的。
国际税收筹划的主要方法
国际税收筹划的主要方法
1.税务优惠政策的利用：不同国家和地区的税法之间存在差异，企业可以通过利用这些差异来降低税负。
例如，一些国家会对外国投资提供税收优惠政策，企业可以选取适合的国家或地区设立子公司或分支机构，来享受优惠政策。
2.跨国转移定价：跨国企业可以通过在不同国家或地区的关联公司之间进行合理的产品定价，来实现税收筹划。
通过将利润转移至税率较低的国家或地区，降低税负。
3.控股公司设立：企业可以在税率较低的国家或地区设立控股公司，将利润和知识产权转移到该公司，以减少税收。
这种操作需要严格遵守当地的税法规定，避免被认定为合理避税。
4.税收协定的利用：不同国家之间存在着双重征税的问题，即同一利润在多个国家被重复征税。
通过利用国际间的税收协定，企业可以选择适合的国家或地区进行投资，避免双重征税。
5.利润转移至低税率国家或地区：企业可以通过在高税率国家或地区设立较低税率的关联公司，将利润转移至低税率国家或地区，来降低整体的税负。
这需要进行合法合规的业务操作，在税务审查时需要提供足够的证据。
6.利用国际金融中心：一些国际金融中心地区提供了较低的税率和灵活的资本流动，企业可以通过在该地区设立分支机构或注册公司，来实现税收优惠和资金管理的便利。
7.跨国并购和重组：企业可以通过跨国并购和重组来重新组织业务结构，实现税收筹划的目的。
通过收购或合并具有较低税率的企业，降低整体的税负。
8.地区特殊经济区的利用：一些国家或地区设立了特殊经济区，提供了更为优惠的税收政策和经营环境。
企业可以选择在这些特殊经济区开展业务，来获得税收优惠。
外文翻译---企业中的税收筹划：以孟加拉国为视角
中文6270字XXX科技学院学生毕业设计（论文）外文译文院（系）经济管理学院专业班级会计学本科2006级学生姓名XXX学号XXX译文要求1.外文翻译必须使用签字笔，手工工整书写，或用A4纸打印。
2.所选的原文不少于2万字印刷字符，其内容必须与课题或专业方向紧密相关，注明详细出处。
3.外文翻译书文本后附原文（或复印件）。
译文评阅评阅要求：应根据学校“译文要求”，对学生译文的准确性、翻译数量以及译文的文字表述情况等作具体的评价。
指导教师评语：指导教师（签字）年月日译自：Social Science Research Network企业中的税收筹划：以孟加拉国为视角斯瓦潘库马尔巴拉，FCMA达卡大学，达卡副教授会计及资讯系统系摘要：本文强调了税收筹划在孟加拉国的问题范围内的经营环境。
由于在复杂的和模糊的孟加拉国现行税法中，这个文件包含了传统的税务规划战略装置以及一个简短的税务规划。
财务筹划是非常有用的被现有的和潜在的商人所期待的税法的有关规定（附录提到在一个非常有组织的方式）。
关键词：税收遵从，税收最小化的有效税收筹划，税务策略，税收优惠。
1 导论税务筹划这一学术术语在经营中包括三个主要词：税务，规划和业务。
“税务是国家强制要求的贡献”——议院英文词典（1992年）。
税款这一专业术语是指被强制的义务，无偿支付给政府——（经济合作组织，1988年：37；随威尔金森，1992.2）。
规划是“预先的决策过程中实现既定目标的必要因素;设计一种有效的方式来达到一些未来目标（结尾）”——柯勒会计词典（库珀和依基瑞，1984.383）。
商业的意思是“不断开展商业或贸易，包括资金投入和以出售商品或服务获得收入作为主要目的”——柯勒会计词典（库珀和依基瑞，1984.378）。
根据第2部分（14）所得税条例（国际贸易组织），1984，商业包括任何贸易，商业或制造，或任何冒险或涉及自然交易，商业或制造业。
1因此，商业税务筹划在企业自愿遵守有关税法规定后，确保税收实体在税务事项后的投资回报率最大化。
外文翻译---浅谈房地产开发企业的税收筹划
译文：浅谈房地产开发企业的税收筹划学生姓名学号院系经济与管理学院专业会计指导教师完成日期Of tax planning for real estate enterprisesAbstract: Corporate tax planning refers to the taxpayer under the tax laws of therelevant provisions of the Tax matters of the enterprise to reduce the tax burden, help toachieve corporate financial goals of the measures and arrangements. Therefore, tax planning is different from tax evasion, tax evasion, is a key financial management business activities. This according to the characteristics of the real estate industry, respectively, from real estate project, construction and sales stage should take into account the tax planning, has great practical significance.1 IntroductionTax is the enterprise Zaisheng Chan operations free of charge to the Government to pay a charge, compulsory and free Xing, business as an independent business Zhu Ti, can, under the premise of the reasonable and legitimate, as Jianshao taxes to bring an 负担revenue reached a low. Business activities of tax planning as an important event, is certain of the objective conditions exist, and Now it seems at least include government taxes of Shui Ping Hu Tax Law Changes Qingkuanglianglei Yinsu. Tax Planning in a large extent is the use of the benefits of accounting policy choice. China’s tax laws and accounting codes specify the enterprises the extent permitted by law and regulations of their selections accounting policies, offers enterprises a reasonable tax avoidance Kong Jian, stressing a point of view of real estate accounting policies the main form of Tax Planning.First of all taxes according to law is a prerequisite for tax planning, tax planning is based on the existing tax system, if an area is not the actual operating revenue based on existing tax law, but to other factors like income index based on, then to Tax Planning for the actual meaning will be lost, which is tax planning enterprises should pay attention to important issues. Second, the existing tax law as a legal stability, also has some flexibility, so a tax planning should always pay attention to tax law changes. In the system transition has not been completed, more frequent tax adjustment stage, this particular attention, because once the adjustment of tax law, tax planning may disappear or change the basis to plan the result may well be planned with the original expectations of the opposite. Therefore, enterprises should pay attention to policy makers and financial personnelchanges in Tax Law and adjust, and adjust accordingly tax planning strategies and programs. Any tax adjustments, the content itself is the basis for the new tax planning.Tax planning by the three operational levels of composition: ○1primary tax planning: avoiding over-tax business. ○2Intermediate Tax Planning: Optimizing corporate tax strategy. ○3senior tax planning: towards a favorable tax policy. Real taxplanning is a rational business continued to mature, and the symbol of a growing awareness of a business tax performance. In the context of tax law, taxpayers are facing a variety of different tax options tax program, taxpayers can be evasive, choose a low tax burden of the programs, business tax planning is a reasonable maximum extent permitted by the tax law reduce the corporate tax burden.2 empirical factOne should consider the project in Real Estate Tax PlanningReal Estate Tax planning is a matter of overall co-ordination offinancial management activities, project phases in the real estate taxplanning is most important.A selection of suitable housing meansMost enterprises tend to own real estate construction and sales of real estate, planning in this way less space, if used on behalf of the building, in building, etc. are planning larger space.(1) real estate on behalf of the CCB. This approach means the real estate development business real estate on behalf of customers to charge their clients on behalf of the construction of income. On the real estate development enterprises, has made some income, but still no transfer of property ownership, its income is labor compensation, the tax base for the business tax, land value-added tax is not a category. Real estate development companies can use this way to reduce the tax burden, but only in the earlystage of development will determine the end-user, the implementation of targeted development, to avoid the development of land after the sale to pay V AT.(2) cooperative housing means. According to “Business Tax Questions (1) notice”requirement, “cooperative housing”means a party to provide the land use right, other funding, the cooperation behavior of housing construction. After the completion of housing allocation in proportion to their own use, except that the prices of land value-added tax; completed the transfer, and then requiring the payment of land value increment tax. In addition, cooperative housing or land shares to intangible assets, shares of real estate investment. Investment. Participate in receiving the investment profit distribution and jointly bear the investment risk behavior, not to collect sales tax; on the share transfer is not the business tax. Businesses can take advantage of these preferential policies, to achieve win-win situation.2 many real estate developmentReal estate development at the same time when many real estate can be accounted for separately, can also be combined accounting, tax paid in tow ways different, select the accounting method for business tax planning in space provided. In general, the merger of the interests of larger tax accounting, but there were more favorable accounting of the situation, specifically how to account for: the need for companies to be analyzed and compared according to the specific situation.Example 1 Changchun real estate company has also developed a two in the city’s real estate, office real estate sale price of the first 1000 million, net of costs under the tax law, 400 million; second office for the 15 million real estate sale prices yuan, according to deduct the cost of the tax law 10 million yuan. If the companies have chosen to separate accounting, the first value-added real estate office was 600 ÷ 400 = 150%, should pay the land value-added tax 600 ×50% -400 ×15% = 240 (million）, business tax and an additional 1000 × 5.5% = 55 million; Second Department of real estate appreciation rate of 500 ÷1000 = 50%, land value increment tax payable 500 ×30% = 150 (million); business tax and an additional 1500 ×5.5% = 83.55 (million). The real estate company’s profit (not considering other taxes) 1000 +1500-400-1000-240-55-150-83.55=5.7145 million yuan. Should the merger accounting, the sale of two real estate prices for 25 million yuan, according to tax law provides for deducting expenses for the 14 million yuan, value added for the 11 million yuan, value-added rate of 1100 ÷1400 = 78.5%. Should pay the land gains tax 1100 × 40% -1400 × 5% = 370 million business tax and anadditional 2500 ×5.5% = 1.375 million. Without regard to other taxes, the real estate company’s profit for the 2500-1100-370-137.5 = 8.925 million yuan. The tax planning to reduce tax burden 892.5-571.45 = 3.2105 million yuan.Second, real estate projects, the city should consider tax planning1 by increasing the deduction for tax planning on the land value increment taxLand value increment tax is one of the major costs of real estate development , construction and land value-added tax rate of no common standards for residential over 20% value-added case can be exempt from that companies can Zengjiakouchu Xiangmushide the added value of real estate does not exceed 20%, which enjoy duty-free treatment.Example 2 Changchun, a real estate company development a common standard of housing, housing for sale at 10 million yuan, according to tax laws can deduct the cost of 800 million value added of 200 million value-added rate of 200÷800 = 25%. The real estate company needs to pay land gains tax 200 × 30% = 60 (million), sales tax, 1000× 50% = 50 (million), urban maintenance and construction tax and education surtax 50× 10% = 5 (million). Without regard to income tax, the real estate company’s profits for the 1000-800-60-50-5 = 85 (million). If the real estate tax planning, the housing for simple decoration, the cost of 200 million, housing prices increased to 12 million yuan. In accordance with the provisions of the tax deductible items increased to 10 million yuan, value added of 200 million value-added rate of 200 × 1000 = 20%, do not need to pay the land value increment tax. The real estate companies need to pay business tax 1200 × 5% = 60 million; Urban Maintenance and Construction Tax and Education 60×10% = 6 (million). Without regard to income tax, the real estate company’s profits for the 1200-1000-60-6 = 134 (million). The lower corporate tax planning tax burden 134-85 =49 (million)2 related to the planning of practical interest loansAs most of the development of real estate ventures financed by borrowing, with ample funds, long term loans, interest, costs more, etc., so we can use the appropriate method of interest deductions on loan interest for tax planning.(1) before the completion of real estate development for the interest cost of borrowing can be completed before the total interest cost of human development, and can calculate the cost of real estate development (period costs) net of the base. Particularly those engaged in real estate development business, but also to obtain land use rights according to the amount paid and the estate and development costs, plus 20% of the net, which can greatly increase the deduction, reduce the value added from the tax base both ease the tax burden and tax rates.(2) for real estate development and interest expenses after completion, all projects can be calculated by the transfer of real estate, assessed and provided proof of financial institutions: be deducted, but the maximum of the same year loans by commercial banks, the amount of rates; who can not be calculated by the transfer of real estate development projects shared interest or can not provide proof of financial institutions, real estate development costs to obtain land use rights according to the amount paid and the real estate development costs and 10% of the calculated and deducted. Enterprises can choose according: If the purchase of real estate rely mainly on debt financing, a higher proportion of interest expense, provides proof of financial institutions, deducted. Instead, rely mainly on equity capital financing, interest costs are low, can not calculate the share of interest, so you can deduct real estate development and more cost beneficial to achieving enterprise value maximization.3 separate sales and fitting, decentralized operating incomeWith the renovation costs in the housing fund to increase the proportion of each year, if the real estate companies sign contracts with home buyers can get a little work around an unexpected effect. If the real estate company set up a decoration company in advance, also signed two contracts with customers: a home sales contract, a housing renovation contract, you only need to specify the amount of the first contract to pay land value increment tax, the second contract do not pay land value increment tax, the tax base and tax rates reduced, thus reducing the tax burden.The choice of real estate sales methods for tax planning is also a good way, by changing the sales model of planning can not only directly reduce the tax burden, and can indirectly obtain the benefits of the time value of money. This mainly involves two aspects.A new subject for the tax divisionThat is to say, real estate operating companies can set up an independent salescompany is responsible for real estate sales, this dexision of land value-added tax, business tax, enterprise income tax planning is very big.Example 3 Changchun, a real estate company selling the ordinary residential project in the amount of deduction allowed under the premise of the same, can use the following selling prices.○1If the price of selling 15 million yuan, the deductible amount of 11.675 million yuan project, value-added rate of 28.48%, the land value-added tax payable 997,500 yuan, net profit of 2,327,500 yuan. ○2The sale price of 14 million yuan, the deductible amount of 11.6696 million yuan project, value was 19.97%, exempt from land value increment tax, net profit of 2,330,400 yuan. ○3If the real estate company set up an independent housing sales company, then the real estate company with 14 million yuan can be the ptice of housing sold to marketing companies, and then again by the sales company to sell for 15 million yuan, when the developer sold to sales company, because of its added value was 19.97%＜20% of the land exempt from V AT. When the sales company 15 million yuan were sold, net of business tax and surcharges Total: 1500×5.5% = 82.5 (million), the amount of deductible items for the 1167.5 +82.5 = 1250 (million), its value was 16.67%＜20% of the land exempt from V AT. From the global point of view, marketing, business tax and other taxes increased by only 1400× 5.5% = 77 (million), given profits 1500 –(1167.5 + 77) = 255.5 (million), compared with pre-planning to increase 255.5-232.75 = 22.75 (million dollars).2 to reduce the carrying amount of deferred tax income or time(1) development enterprise free or charge very little handling consignment sales, real estate, and can consult the list issued by sales, because in this way receive the consignment on the basis of actual sales for the list of units to sell when the implementation of recognition of income, so recognized liability arising can be deferred as far as possible, while such sales of the company to avoid paying sales taxes.(2) the original commitment by the development of enterprise sales and management costs passed on to the sales company to sell the company to reduce or even do not pay corporate income tax. Of course, for entertainment expenses and advertising fees are net of fees deduction limit, it should be prior consultation to determine the development of enterprises themselves, in order to avoid these costs exceeded the increase was a result of taxable income situation.(3) means for customers to purchase mortgage product development, its first day ofactual receipt of payment confirmation should be the realization of income, balance transfer apply for mortgage loans in the bank to confirm the date of realization of income. So as much as possible in consultation with clients and banks, to open the specified collection accounts, mortgage repayment of part of the customer deposit accounts regularly first, then go through phases when the re-confirmation transfer and income tax.The basic principles of tax planning is legitimate under the premise of the taxpayer, the tax scheme chosen lighter tax burden, in order to reduce cash outflow, increase disposable funds to maximize their own interests to achieve a kind of economic activity. Enterprise in the fixed assets of routine maintenance, disposal, depreciation extraction process, also should consider the impact on taxpayers. China’s tax laws and accounting policies and other relevant laws and regulations specified in the enterprise can be permitted within the laws and regulations to choose their own accounting policies, which provides a reasonable tax avoidance to the enterprise space, different accounting policy choices will lead to different corporate tax negative, so companies should carefully choose the accounting policy. Real estate business involves more than tax links, and a heavier tax burden than other enterprises, the accounting policy on the use of tax planning of real estate companies to analyze, including the following points.A use for bad debts for tax planning.Enterprises often have bad place, especially the real estate business. Bad debts that occurred after the tax authority can be used for bad debts charged against taxable income, saving income tax paid. But to note that not all bad, as bad debt losses can handle. Thus, tax avoidance must be clear under what conditions can be as bad debts. In addition, the company has accounts receivable as bad debt losses, in the future to recover all or part of the year, and should be included as taxable income to recover the amount.2 use of depreciation, depletion and amortization method of accounting into OK Tax PlanningDepreciation of fixed assets, intangible assets and deferred assets are allowed to deduct income tax before the project, established in the case of income, the greater the amount of depreciation and amortization, less the amount of taxable income. Accounting depreciation methods available to many, accelerated depreciation is a more effective and reasonable means of avoidance. In addition, the enterprise financial system, although the depreciation period of fixed assets, amortization of intangible assets and deferred assets,made a classification of the provisions of the period, but also a degree of elasticity, the absence of clearly defined asset depreciation or amortization period may be shorter as we choose number of years. Shorten the depreciation period is conducive to accelerated cost recovery, cost can post in advance, so early after the shift accounting profits. In the case of tax rate, tax deferred pay, equivalent to an interest-free loans made to the state.3 use of sales price for tax planningProvisions that the construction of common standards for residential taxpayers to sell value added does not exceed 200% of the amount of deductible items, the exemption of land value-added tax; appreciation amount exceeding 200% of the amount of deductible items, shall be required for its full value-added tax. Taxpayers should seek to enjoy the tax exemption of tax concessions.It is assumed, a real estate development of commercial housing sales price of a, 5% sales tax, urban maintenance and construction tax rate is 7%, 3% surcharge for education, in addition to sales tax and additional amount of deductible items outside of b, then Full deduction amount: b +5% a (1 +7% +3%) = b +5.5% aTo enjoy the exemption benefits, added value must be less than 20%, obtained: [a-(b+5.5% a)] / (b +5.5% a) <20%Solution of the above inequality can see, a <12848b, the taxpayers want to enjoy the exemption from land value increment tax concessions, the sales could not exceeding the sales tax and additional amount of deduction than 12,848 times, or will the full tax. Can see from the above reasoning, when a = 12484b, the added value of just 20%. When the value was slightly higher than 20% should be applied “value-added rate of 50% or less, the tax rate is 3%”rule. Assume that prices increased to a + x (ie 12848b + x), the corresponding sales tax and additional increase of 55 Am, is: deductions allowed amount = b +5.5% a +5.5% x = b +7.0664% b + 5.5% x = 107.0664% b + 5- 5% x value added;1.2848b + x (107.0664% b +5.5% x) = 21.4136% b +94.5% X. Land value increment tax payable is 0.3× (13.6% b +94.5% x) = 6.42408% b +28.35% x.If taxpayers want to increase profits by raising prices, they must be x> 6.42408qd~, - 28.35% x, or x> 0.0897b. That is, if you want to achieve by raising the price of greater income, we must make the price exceeding the sales tax and additional amount of deduction than 13,745 times (ie 12 848 +0.0897).From the above analysis, the taxpayer sold real estate prices in the determination of rules to be followed is that when the addition to the sales tax and the additional amount after the deduction b when setting the price 12848b is the taxpayers can enjoy tax-freeoffers the highest price. This price can enjoy greater tax benefits they receive, if the price below that price, though also enjoy tax exemption, but only for low income, any increase in price, you must make the price higher than the 1.3745b, otherwise the benefits of higher price will not be enough to make up for higher prices by increasing the tax burden. When the tax rate jumped from 30% to 40% of such circumstances according to push to draw the best of each file tax threshold criteria for determining the price.4 use of income recognition for tax planningWith the consumer’s personal housing requirements of a real estate business from the original rough housing development to decorate rooms, and renovation standards increase year by year, fitting-out costs in the housing fund to increase year by year the proportion of middle, so that the selling of Real Estate room revenues by the Fang Jiakuan and fitting models of two parts. According to China’s tax law, corporate sales of commodity houses by sales amount to 5% for the business tax to provide decoration services in accordance with the decoration of the contract value of 3% to pay business tax, urban construction tax and education tax added Junan business tax of 11% of pay, while still the land value tax and deed tax, if the price of commercial housing decoration is included in the price, by real estate companies will pay more sales tax and land value-added tax. Besides, given the relatively high unit value of real estate, the buyer is difficult to produce large amounts of money to buy one, which can be used to confirm income installments, rather than total income recognition Anzhao price so that you can split the corresponding node transfer costs, play a tax saving effect.5 using the accounting treatment of employee wages for tax planningWhen calculating the taxable income deduction of wages of workers in two ways: First, the wage tax means the total tax payment of wages within the standard, deducted; more than the standard deduction shall not part. The other is total wages and economic methods of linking, average wage growth rate lower than the growth rate of labor productivity within, in the calculation of taxable income may be deducted. Alternative approaches in the two cases, poor efficiency in the Mainland enterprises adopt the first method, or better efficiency in the coastal enterprises adopt the second approach, as far as possible controls in the taxable wage workers income within the deductible. Another conversion at reasonable cost may be tax planning, such dividends paid on employee ownership can be paid out year-end bonuses, to increase costs; sales staff salaries bonuses and reasonable business expenses into by bun form of incentive pay, Tax can bereasonable.6 use of investment tax planningOn the accounting treatment of long-term investment cost method and equity method, the choice of two methods for tax planning can result in a certain space. Because the cost of its investment income realized but not before the sub-return investments, the investment company’s “investment income” account does not reflect realized investment gains, while the equity method investment earnings regardless of whether the points back, both in the investment business “investment income” account to reflect. Thus, companies using the cost method can be invested enterprises will be paid by the investment income were invested in long-stay business account as a capital accumulation can also be used for other purposes, to avoid some long-term investment income should be in back corporate income tax. Therefore long-term investment and short-term investments can be found standard reference point. Without prejudice to the relevant provisions of the State under the premise of the application of cost as much as possible or as much as possible to identify short-term investment of an investment will help reduce the cost of paying taxes.7 full use of the taxable income before tax adjustments for tax planningAlthough the adjustment of taxable income by the Inland Revenue Department is to test, but if some method can make the wages, hospitality, advertising fees are not excessive, these methods are reasonable avoidance measures, the boundaries between legal and illegal users were required under circumstances to make the necessary professional judgments. In addition, if some projects not up to standard, other excess may be related to the swap, so that the whole is not exceeded. Of course, this requires some degree of good grasp. As the real estate business expenses each year is a huge advertising costs, advertising expenditures and sales are closely linked, each year, spending 2% of sales. Threshold can be deducted, if the cost of advertising by the Corporation unified plan, agreed to pay, advertising costs are likely to arise out of proportion head case and not in the tax deduction, while the other costs associated with the company’s advertising reach this ratio is also, when advertising costs can be achieved to the reasonable transfer of associated gas transportation.3 theoretical effortWhen the existence of two or more tax options, companies should design andlogistics, to achieve the minimum, a reasonable tax. Although the adjustment of taxable income by the Inland Revenue Department is to test, but if some method can make the wages, hospitality, advertising fees are not excessive, these methods are reasonable avoidance measures, the boundaries between legal and illegal users were required under circumstances to make the necessary professional judgments. In addition, if some projects not up to standard, other excess may be related to the swap, so that the whole is not exceeded. Of course., this requires some very good degree of certainty, must also follow the basic principles of tax planning:.(A)consider the complementary economic environmentThe more developed the local real estate economy, the more intense competition, companies, must find ways to cut costs, the greater the demand for tax planning, and thus the greater the impact of local government. Government policy on tax planning guidance and whether we should decide how to encourage, which involves various government functions, the real deciding whether the preferential policies provided certain criteria are often not the tax authorities, enterprises should make full use of other functions right of approval, to obtain tax relief eligibility. Level of the tax authorities on the business of law enforcement capacity to have a great impact on tax planning.(B)to follow the principle of cost-effectivenessAny planning program has its two sides, with a particular implementation of the program planning, business interest in obtaining some of the same time reduce the tax burden will definitely pay extra for the implementation of the program costs, and lost by giving up other programs corresponding opportunities for income. When the new costs incurred or loss when less than the benefits obtained, the planning program is reasonable, when the costs or losses greater than the benefits obtained, the planning program is the failure of the program. A successful tax planning must be a variety of programs optimized. The lightest tax burden can not be simply that the program is the failure of the program. A successful tax planning must be a variety of programs optimized. The lightest tax burden can not be simply that the program is the best tax planning program.(C) the proper understanding of the principles of tax law and accounting separationBecause of different accounting and tax law purposes, the basic premise and the principle followed in some differences in tax planning must take into account the tax laws and corporate accounting system appropriate separation is inevitable.1.For different purposes. The purpose of the development enterprise accounting system is to truly and completely reflect the financial condition, results of operations and changesin financial position of the picture, for the statement users to provide decision useful information. Fundamental point is to provide investors or potential investor fully understand the veracity of corporate assets and earnings potential. The main purpose of the tax law is to get the country’s fiscal income, adjusted economic and social development. Different purposes, both times on the same issues of economic behavior or make a different specification requirements.2. Different basic premise. The basic premise of accounting, including: accounting entity, going concern, accounting stage, monetary measurement. Accounting to determine the object, the choice of accounting methods, accounting data collection and so on to the basic premise of accounting basis. Since the purpose of tax accounting system and different, so the basic premise of the two differ. Accounting of the main information needs of persons in accordance with the accounting requirements of accounting units, can be a subject of law, it can be an economic subject. Taxpayer is directly liable to tax according to law, the basic tax units (or natural), that is, the individual taxpayer tax law. Accounting period, as accounting systems and tax laws for different purposes, on income, expenses, assets, liabilities, etc. to confirm time and scope are sometimes not the same, thus resulting accounting profit before tax and taxable income differences between the produce-timing differences and permanent differences.3.Follow different principles. As the corporate accounting system and tax laws serve different purposes, leading to two different purposes for the realization of the principles are quite different. Tax also follow some basic principles of accounting, but insist on the legal principle of tax law, income and balanced principles of fairness, anti-avoidance principles and facilitate the collection and management principles, such as sound or prudent principle, and many other basic principles of accounting the departure from the use of another. Above all these differences in tax planning programs need to be taken into account.In 2006 the Ministry of Finance issued a new “Enterprise Accounting Standards”, of which 38 specific standards have varying degrees of change in accounting subjects and deal with major accounts have made the new requirements. China’s tax reform has also entered into a comprehensive implementation phase, the State personal income tax reform in 2006, Xiaofei tax reform based on the mid-2007 has steadily V AT, corporate income tax, “the two France Hebing”, personal income tax, resource tax dollars tax method, the standard land-use tax increase, tax policy adjustments and the introduction of international anti-tax avoidance policies such as a new series of major reforms.。
企业所得税税收筹划研究外文翻译文献
企业所得税税收筹划研究外文翻译文献(文档含中英文对照即英文原文和中文翻译)Study on the Tax Planning of Enterprise Income TaxHongceng Cao & Xiaohui XuCollege of Economics, Shenyang UniversityShenyang 110044, ChinaGuojie AoDepartment of Accounting and Financial Affairs, Shenyang UniversityShenyang 110044, ChinaAbstractThe enterprise income tax occupies is very important status in the tax paying of enterprise, and it has large space of tax planning. Under the background that the new enterprise income tax law was issued, we discussed the problem how to use tax planning to reduce the tax burden of enterprise and realize the maximization of the total profit for the enterprise. In this article, we studied the tax financing in the stage of enterprise financing from the selection of financing mode and the confirmation of financing channel, and put forward that the enterprise should select the liability financing mode to the largest extent in the critical risk range of equity structure. We studied the tax planning in the stage of investment of enterprise from three aspects including correctly selecting theinvestment direc tion, confirming proper enterprise organization form and selecting tax saving investment subject. We studied the tax planning from two aspects such as income and charge deduction. We studied the tax planning in the distribution stage of enterprise management result from first utilizing taxable income to compensate the loss, the loss recovering sequence of domestic investment profit return and the profit distribution strategy in the low tax region. For above aspects, we all put forward our own new theoretical opinions.Keywords: Enterprise income tax, Tax planning, Tax preferenceComparing with the old enterprise income law, the new enterprise income law changed in many aspects such as the taxpayer, the pre-tax deduction, and the tax preference, which put forward new task for the tax planning of the enterprise income tax. Under the background of new enterprise income tax, we will discuss the tax planning in the main stages such as the enterprise financing, investment, management and distribution.1. Tax planning in the stage of enterprise financingThe tax planning of the income tax in the stage of enterprise financing mainly includes the contents about the financing mode and the financing channel.1.1 Tax planning of financing modeThe financing modes of enterprise mainly include the equity financing and liability financing, and two different financing modes will produce different tax results. Generally speaking, under the fixed tax rate level, the liability financing can produce the interest rigid cost which can be reported before tax. When the account profit is adjusted as the taxable income, the tax law allows that the interest expenditure induced by the liability can be deducted before tax in the same interest rate regulated by the Bank in the same period, which equals that the state finance assumes a quarter of interest cost fro the enterprise. The equity financing is the flexi ble cost of bonus stock which can be reported after tax. The mode that the enterprise provides bonus stock and dividend to the investors is only one item of the distraction of post-tax profit (net profit), and it must be distributed after tax. The tax saving difference between two financing modes is very obvious. In the equity structure of enterprise, the proportion of the liability equity is higher, and the saving effectof the tax cost is more significant. So under the prem ise that the rate of or return on inv estment is higher than the liability cost rate, enhancing the proportion of liability financing will bring extra economic benefits for the owner of the enterprise, and finally increase the value of the enterprise. But we should also pay attention to that will increase the financial risk of the enterprise, and excessive liability will even induce the ab normality of the enterprise equity structure, and the liability crisis will make the financial status of the enterprise fall into collapse. Therefore, before the enterprise makes the tax planning of financing mode, it must ensure that the equity structure is in the critical risk range.1.2 Tax planning of enterprise financing channelThe financing channels of enterprise mainly include bank loan, self-accumulation of enterprise, inter-enterprise lending interior collection of en terprise, bond or stock issuance and commercial credit. Under usual situation, the sequence of the tax burden from heavy to light is self-accumulation of enterprise, bank loan, inter-enterprise lending and interio collection of enterprise. The prin ciple of tax planning of financing channel is that under the premise that the equity structure is to select the channel with higher profit and lower harm in the critical risk range, through comparing the advantages and disadvantages of various financing channels.2. Tax planning in the investment stage of enterpriseFor the tax planning in the investment stage of enterprise, we mainly consider three aspects, i.e. the selection of investment direction, the selection of enterprise organization form and the selection ofinvestment mode.2.1 Selecting correct investment directionThe new enterprise income tax established the new tax preference which gave priority to the industrial preference assisted by the regional preference, giving attention to the social advancement . Investors should select the investmen industry to reduce the tax burden according to the regulations about the national industrial policies and tax preference and response the industrial policy gui dance of the government. First, because the industrial select possesses strategicmeanings for the development trend of the enterprise, so when the investors make the decision of industrial investment they should scientifically demonstrate the investment and carefully make the decision, and they should consider not only their own industrial advantages, but also national industrial support policies, industrial tax preference policies, and make the rare resources of the enterprise to the green sunrise industries such as the agriculture, scientific technology environment protection and energy saving. Second, the enterprise income tax regulated regional preference for Chinese western regions, minority regions and special economic zones, and the enterp rise should study out multiple selectable investment programs in possible investment regions, and it should not only compare the cost incomes of various regional investment programs, but compare the tax levels of various programs, and make the comprehensive evaluation for the comprehensive benefits of variou s regional investment programs, which can not only reduce the tax burden, but find the regional investment program with maximum economic benefit.2.2 Selecting proper enterprise organization formThe tax planning of enterprise organization form should mainly consider four parts including establishment, expansion, division and merger. First, we will study the tax planning when the enterprise is established and select the organization form. According to the organization form, the enterprise types include individual proprietorship enterprise, partnership enterprise and limited corporation which can be divided into limited liability company and joint stock limited partnership, and because the tax system regulates different tax burden levels for the enterprises with different organization forms, so the establishment costs and advantages of different organization forms are different, and the tax is one of factors we should consider when we select the organization form of the enterprise. Especially when the organization form of the enterprise has large influence to the production and management, the tax will be the important factor which we should consider, and investors can select the organization form of the ent erprise to reduce the tax burden for the enterprise. Second, we will research the tax planning when the enterprise is expanded and needs to select the organization form. Enterprise always actualizes the scale expansion by increasing branches, but the tax policies for the branches with different forms in the tax law are obviously different, so enterprise should select the organization form of the branch. For the filiale and the subsidiary company, they respectively have their advantages and disadvantages for the tax, so the loss of the branch can counteract the gain of the parent company and reduce the total taxable income of the company. The subsidiary company and the parent company are regarded as two entities in the law, but the subsidiary company can obtain various tax preference policies regulated by the laws or local government. So the enterprise should comprehen sively consider the profit ability of the branch when it selects the form of the branch, and it should adopt the form of filiale when the branch is in the loss period, and adopt the form of subsidiary company when the branch is in the profit period. Third, we will study the tax planning in the division and merger of the enterprise. According to the regulations of the enterprise income law, enterprises should pay the income tax by 25%, but it also regulates that the small-sized profit-mak ing enterprise can pay the income tax by 20%, so the middle and small-sized enterprise can adopt the division measure to separate the branch from th e enterprise to reduce the taxable income and the tax burden. Theenterprise income tax regulates that the profitable enterprise a nnexes unprofitable enterprise, it can use the accumulated loss of the unprofitable enterprise to counteract the profit of the profitab le enterprise and reduce the taxable income and the tax burden. Therefore, in the merger of enterprises, the profitable enterprise can reduce the enterprise income tax by annexing unprofitable enterprises.2.3 Selecting the investment subject of tax savingAccording to different forms of investment subject, the investment of enterprise can be divided into monetary investment, tangible investment and im material investment. The monetary investment doesn’t increase the tax burden of investors, but it w ill influence the cash flux and payment ability of the enterprise. Different tax regulations aim at different tangible investment types, for example, fo r the estate investment, investors need not pay relative sales tax (if investor belongs to the real estate enterprise, the land value increment tax needs not be paid temporarily), and the depreciation of the estate can be deducted before tax to reduce the tax base of the en terprise income tax. For the sock-in-trade investment, the tax law will regard it as the sales goods and increase the tax bases of the value increment tax and the enterprise income tax, and the enterprise need pay the increment tax and the enterprise income tax. The immaterial investment can deduct the withholding income tax for the enterprise, and realize the deduction before tax through amortization year by year, which can reduce the tax base of the enterprise income tax. So when the enterprise selects the investment subject, it can select the tangible investment and immaterial investment which are better than the monetary investment from the view of the invested enterprise. Certainly, for the view of investing enterprise, it will assume more tax burdens such as the enterprise income tax, the increment tax and the consump tion tax when it selects the tangible investment and immaterial investment, so the investing enterprise should comprehensively consider the tax burdens of two parties to select the proper investment form.3. Tax planning in the production and management stage of enterpriseThe tax base of the enterprise income tax is the taxable income amount which equals to that an enterprise’s total income amount of each tax year deducts the tax-free incomes, tax-exempt incomes, each deduction items as well as the permitted remedies for losses of the previous years. And the income items, tax-free incomes and tax-exempt incomes and each deduction items are all generated in the production and management of the enterprise. So the tax planning of the enterprise income tax in the production and management can be implemented from two items such as the income items and the deduction items.3.1 Tax planning of incomeThe total income amount of the enterprise in the present term is decided by the sales amount of the product, the unit sales price of the product and the selected sales mode of the product, so the tax planning of the enterprise income tax about the income mainly includes the scale of production and sale, the sales price and the sales mode. First, for the planning of production and sale scale, under the premise of certain sale unit price, the income scale of the enterprise is decided by the sales amount. The scale of production and sale belongs to the item independently controlled by the enterprise, and the scale of production and sale will influence the tax burden of the enterprise which will influence the scale of production and sale in the same way. Therefore, when the enterprise confirms the scale of production and sale, it must consider the tax burden at term. According to the en terprise’s self management ability, the enterprise should find the critical point of profit and loss, and seek the scale of production and sale with maximum profits. Second, for the planning of sales price, under the premise of certain production and sale amount, the income scale of the enterprise is decided by the price level which is also the item independently controlled by the enterprise. The enterprise should consider many factors such as the cost level, the market de mand and thecompetition strategy, and the tax burden level is the important factor which should be considered by the enterprise, and the confirmation of the sales price can not only include the pre-tax income and income tax of the enterprise, but will directly influence the increment tax and other relative taxes. In the tax planning of income, we should take the sales price as the factor we should mainly considered. Third, for the planning of sales mode, in the sales proce ss of the product, the enterp rise possesses the independent selection right to the sales mode, and different sales mode always apply in different tax policies, i.e. the treatment difference of tax exists in this aspect, which offers the possibility to utilize different sales mode to plan the income tax. In a word, under the premise disobeying the tax law, the enterprise should compress the income scale which has exceeded the critical point of the tax rate from the sales scale and the sales price, and make the enterprise obtain the preference policies of low tax rate. For the selection of sales mode, the enterprise should delay the implementation of the income and the tax obligation to the best, which will not only compress the income scale in the present term to make the enterprise obtain the preference policy of low tax rate, but also make the enterprise obtain the profit of interest-free loan because of delaying the implementation of tax obligation.3.2 Tax planning of cost charge deductionThe payout of the enterprise can be divided into the profitable payout and the capital payout according to the time of the profitable term. The profitable payout should be reported in th e present cost charge, and the capital payout is divided and respectively reported in the cost charges of the present and future terms. For these two sorts of payout, the planning of the enterprise income tax should treat them differently.3.2.1 Tax planning of profitable payoutBecause different situations of profit and loss, and different tax preferences will differently influence the tax planning of enterprise, so we should respectively plan the tax of the profitable payout aiming at different situations of profit and loss. First, suppose the enterprise is profitable, because the profit able payout can be deducted from the enterprise income tax, the enterprise should select the planning method with large prophase cost. To make the tax deduction effect of the cost exert its function as soon as possible, and delay the realization of the pr ofit, then enterprise should delay the tax obligation time of the income tax. Second, suppose the enterprise is in loss, the planning method should be combined with the loss remedy of the enterprise. The enterprise should try to make the cost charge in the year with pretax loss remedy higher and make the cost charge in the year w ithout or incompletely with pretax loss remedy lower, and accordingly ensure the tax reduction effect of the cost charge will be exerted to the largest extent. Finally, suppose the enterprise is enjoying th e preference policy of the enterprise income tax, because the taxdeduction effect of the cost charge in the tax deduction period will completely or pa rtly be deducted through the deduction preference, so the enterprise should select the planning method which has few costs in the tax deduction period and has more costs in the non-tax-deduction period.3.2.2 Tax planning of capital payoutAs the modernization degree of enterprise is gradually enhanced, the proportion of the purchase payout of the long-term assets such as the fixed assets and immaterial assets which reflect the progress of the technology of the enterprise is higher and higher, and the tax planning of the fixed assets depreciation and the immaterial assets salesmanship possesses special importance in the tax planning of th e enterprise income tax. First, the tax law doesn’t recognize the devaluation preparation of long-term assets which the enterprise picks up, but the taxpayer can utilize the relative regulations about the subseq uent expenses of the long-term assets to adjust the depreciation base. The enterprise should combine the long-term development, rebuild the fixed assetsdesignedly, enhance the technical level of the enterprise, and improve the comprehensive competition strengthen of the enterprise. At the same time , the enterprise can put the subsequent expenses acco rding with the capitalization cond itions into the fixed assets cost, increase the depreciation picking base, and accordingly increase the depreciation amount of the deduction, reduce the taxable inco me of the present term and save the tax. For various payouts which don’t accord with the confirmation conditions of long-term assets, they should be counted into the profit and loss of th e present term. Second, the “Chinese Enterprise Income Tax Law” regu lated that the fixed assets of the enterprise needed to be depreciated quickly because of technical progress, the enterprise could reduce the depreciation fixed number of year or adopt the method of quick depreciation. To reduce the depreciation year can quicken the withdrawal of the costs, move the anaphase cost charges to the anterior period, and move the prophase account profit to the latter period. When the tax rate is fixed, the delayed payment of the income tax equals to obtain an interest-free loan from the country. When the tax rate is not fixed, the extension of the depreciation term can also reduce the tax burden for the enterprise. And the selection of the depreciation method of the long-term assets should be scientific, reasonable and legal. Finally, when the enterprise is in the non-deduction period of the income tax, taxpayer should apply for reducing the residual proportion for the tax department in time according to the characters of the assets. When the residual proportion is reduced , the depreciation tax de duction will increase, which could not only maintain the taxpayer’s right, but bring large tax benefit for the taxpayer.4. Tax planning in the management result distribution stage of enterprise4.1 First utilizing the taxable income to compensate the lossFor the yearly loss of the enterprise, the tax law regulates to allow the enterprise uses the pretax profit in the next year to compensate it. And if the profit in the next year is not enough to compensate, the enterprise is allowed to compensate the loss year after year, but the longest term should be limited in 5 years. In this way, the enterprise can use the selection right of the assets price counting and amortization method allowed by the tax law, and the selection right of the expenses reported range standard to more report the pretax deduction items and deduction amount, and continue to induce the loss before the term of five years is at term, accordingly to prolong the term of the preference policy.4.2 Arranging the domestic investment return to compensate the loss according to the sequence from low tax rate to high tax rateAccording to the enterprise income tax, the investors’ after-tax profits returned from the associated enterprise should pay the income tax, but if the enterprise which is the investor has loss or past yearly loss which has not be remedied, the returned profit can be used to remedy the loss, and for the surplus part, the enterprise should pay the income tax. Therefore, if the investor is the enterprise which can be applicable for different income tax rates, the enterprise can select the sequence from low tax rate to high tax rate, to use th e returned investment profit remedy the loss and make the taxpayer’s income tax reduce to the least level.4.3 Keepin g that the investment return in the low tax region doesn’t be distributedIn the existing enterprise income tax, for the taxpayer’s profit returned from other enterprise which has paid the income tax, the tax amount of the tax payment can be adjusted when computing the income tax of the enterprise. If the profit of the invested enterprise has not be distributed to the investors, the investors need not to pay the income tax, and in this way, to keep that the investment return in the low tax region doesn’t be distributed and turn it into the investment capital can reduce investors’ tax burden.ReferencesChinese CPA Association. (2008). Tax Law. Beijing: Economic Science Press.The Fifth Session of the Tenth NPC. (2007). Enterpri se Income Tax Law of China. Mar. 16, 2007.Wang, Xinjian. (2006). The Method of Enterprise Tax Planning. Shandong Commercial Accounting. No.2.Zhou, Yan. (2008). Influences of New Enterprise Income Tax Law on Enterprise Tax Planning. Friends of Accounting.No.15.Zhuang, Fenrong. (2007). Hundred Classic Practical Examples of Tax Planning.Beijing: Mechanical Industry Press.企业所得税税收筹划研究曹宏层、徐晓慧（沈阳工业大学经济学院）、敖国杰（沈阳工业大学会计财务部）摘要企业所得税的税收空间很大，在企业的纳税额中占有很大的比重。
税收筹划的思路、原则和步骤是什么
税收筹划的思路和步骤是什么？1、全面了解纳税人的情况纳税人是税收筹划的主体，任何税收筹划活动都是围绕纳税人进行的。
因此，在进行税收筹划之前，全面了解纳税人的情况十分有必要。
(1)基本情况。
企业的基本情况包括企业的组形式、成立日期、经营范围、经营规模、关联关系和股权架构等。
企业的组织形式、经营范围不同，其缴纳的税种也不尽相同。
如果企业是股份有限公司，其取得收入后除了要缴纳流转税外，还要缴纳企业所得税。
如果企业是个人独资企业或合伙企业，则不需要缴纳企业所得税，只需要由个人投资者缴纳个人所得税（法人合伙人需要缴纳企业所得税）。
了解了企业的基本情况后，可以做到心中有数，以便抓住主要税种进行税收筹划。
(2)财务情况。
企业的税收筹划要合法地节税，只有在全面和详细了解纳税人财务情况的基础上，才能制订出针对纳税人的税务计划，使税收筹划方案切实可行。
(3)风险态度。
节税与风险并存，节税越多的方案往往也是风险越大的方案，两者的权衡取决于多种因素，包括纳税人对风险的厌恶和偏好程度。
了解纳税人对风险的态度及对风险的承受程度，可以更好地按纳税人的要求进行税收筹划方案的设计。
2、分析纳税人的现行纳税情况在全面了解纳税人情况的基础上，进一步分析其现行纳税情况对于发现税收筹划空间和设计税收筹划方案而言是至关重要的。
企业的纳税情况主要包括涉及的税种、纳税人的类型、计税方式、适用税率、纳税申报、纳税金额、税负状况、减免税情况以及历史上是否存在违反税法的情况等，这对税收筹划方案的制定具有很大的借鉴作用。
3、熟练掌握税收相关法律规定进行税收筹划是在税法允许的范围内，选择少缴免缴或递延缴纳税款的行为。
由于税法的内容相当复杂又经常修订，而纳税人的自身条件也在不断发生变化，所以要想有效地运用税收筹划策略、实现节税目标，必须了解并熟练掌握税收法规。
除此之外，纳税人还要具备投资、生产、销售、财务、会计等方面的法律知识，懂得合法与违法的界限，从而确保税收筹划行为的合法性。
企业税收筹划中英文对照外文翻译文献
中英文对照外文翻译文献(文档含英文原文和中文翻译)1、Enterprises of the major means of tax planningTax planning is the premise of strict enforcement of tax laws to minimize tax, customs tax called. Enterprises to carry out the correct tax, the need for the adoption of the following major route of transmission.First, reasonable means of financing options. In accordance with the provisions of China's current tax law, corporate interest payments on the loan within a certain range can be pre-tax expenses, and dividends can only be spending the after-tax profits of enterprise expenses. From a tax point of view, appropriate to the bank business loans and financing between enterprises, rather than directly to thefund-raising benefits.Second, a reasonable choice of trading partners. China's existing value-added tax system has a general taxpayers and small-scale taxpayers on the points, choose a different supplier object, the tax burden on enterprises is not the same. For example, when the Department of suppliers of value-added tax general taxpayer, the businessafter the purchase of goods, according to the amount of tax deduction of input tax amount of the corresponding balance after payment of value-added tax; if the purchase of goods for small-scale taxpayers, VAT can not be achieved Its not contain the amount of input tax deduction, the tax burden more than the former. Such as open invoices can also be part of deduction.Third, "the easy way out" tax conversion. Enterprises will be converted tohigh-tax low-tax, refers to economic activities in the same, there are a variety of revenue options to choose from, the taxpayers to avoid "high-tax point", choose the "low tax" and reduce the tax liability . The most typical example of this is to runnon-taxable to the tax planning services. From the tax point of view, run mainly two: First, the same taxes, different tax rates. Systems such as supply and marketing enterprises, the general operating tax rate is 17% of the means of subsistence, but also the operating value-added tax rate of 13% of the agricultural means of production and so on. Second, different taxes, different tax rates. This usually refers to types of enterprises in their business activities, both value-added business project, the project also involves the business tax.Fourth, the cost of reasonable expenses. Enterprises does not violate tax laws and financial system under the premise of the full cost of the reasonable expenses, that may occur on the full estimated losses and narrow the tax base and reduce the amount of taxable income. Countries allow for costs incurred in the projects, such as wages, respectively, the total amount of tax by 2%, 14%, 1.5% extracts of trade union funds, staff welfare, staff education funding should be sufficient to mention as much as possible to the whole. For some of the losses that may occur, such as bad debt losses, businesses should be fully expected in the tax law as far as possible the extent permitted by the cap enough to reserve. This is in line with the national tax law and financial system, can receive the tax effect.Fifth, to reduce tax liability. Factors that affect the tax liability there are two, namely, tax base and tax rates, the smaller the tax base, lower tax rates, tax liability is also smaller. Tax planning can start from these two factors to find legitimate ways to reduce tax liability. For example, an enterprise December 30, 2005 estimated taxableincome amounted to 100,200 yuan, the enterprise income tax liability 25050 yuan (100200 ×25%). If the corporate tax planning, tax consulting fees to pay 200 yuan, the corporate taxable income 100,000 (100200-200), income tax liability 27,000 yuan (100000 × 27%), can be found by comparing, for tax planning to pay only 200 yuan, 6066 yuan tax is (33066-27000).Sixth, to weigh the severity of the overall tax burden. For example, manyvalue-added tax planning programs have the general taxpayer and the taxpayer to choose small-scale planning. If an enterprise is a non-tax-year sales of about 900,000 yuan of production enterprises and enterprises to buy the materials each year the price of non-value-added tax of 70 million or less. The company's accounting system, the conditions identified as the general taxpayers. If that is the general taxpayer, the company's products are value-added tax rate applies to 17% capital gains tax liability 34,000 yuan (90 × 17% -70 × 17%); If it is small-scale taxpayers, the rate is 6%, 5.4 VAT liability million (90 × 6%)> 3.4 million. Therefore, from the perspective of value-added tax general taxpayer should be selected. But, in fact, althoughsmall-scale VAT taxpayers pay 20,000 yuan, but the input tax amount of 119,000 yuan (70 × 17%), although it can not offset the costs, thereby increasing the cost of 119,000 yuan, the income tax reduction of 2.975 million (11.9 × 25%), than pay a 20,000 yuan of value-added tax. Therefore, the business tax planning in the selection of programs, not only to look in a certain period of time watching the program on tax less, and to consider business development goals, to choose to increase their overall revenue program.Seventh, take full advantage of preferential taxation policies. For taxpayers, the use of tax incentives for tax planning focuses on how the rational use of tax policies and regulations shall apply to the lower or more favorable tax rates, a well-planned production and operation activities, the actual tax burden to a minimum in order to achieve Festival tax effect. For example, according to China's Law of the State Council for approval of high-tech industrial development zone of the high-tech enterprises, since the production from the fiscal year income tax exemption for 2 years. To-business use of wastewater, waste gas, waste residue and other waste as themain raw materials for production, 5 years in the income tax reduction or exemption. In addition, to support agriculture and the development of UNESCO Wei investment, countries have different tax incentives. Business operators should refer to policy, comparing the investment environment, investment income, investment risks and other factors, decided to invest in the region, investment direction, as well as investment projects, a reasonable tax planning, in order to reduce the corporate tax burden.企业税收筹划的主要途径纳税筹划是在严格执行税法前提下，尽量减少缴税，习惯称其为节税。
税收筹划-外文文献
关于税收筹划的论文税务筹划是纳税人在法律规定许可的范围内，通过对投资、筹资、经营、理财等活动进行事先安排和筹划,尽可能减少不必要的纳税支出.以谋求最大限度的纳税利益，实现企业税后利润或现金流量最大化。
税收对国家来说是为了实现其职能，凭借政治权利按预定标准无偿地参与国民收入分配的一种手段；而对纳税人来说则是资金的净流出，节约税款支付等于增加纳税人的净收益.本文从税务筹划的必然性和如何进行税务筹划两个方面谈一下自己对税务筹划的认识.一、税务筹划的必然性我国是法治国家，纳税人必须根据税法的规定性履行纳税义务。
而纳税必然减少纳税人的净利润，为了在合理、合法、合规的情况下达到节税,实现利润最大化的目标，纳税人必须进行税务筹划。
即，环境是一定的，只有适应环境，才能改变自我。
我们的环境是：来源于市场，适应于市场。
而在市场运行中又必须遵循一定的市场规则，适应、掌握并较好地运用这些市场规则，最终实现纳税额度最低，企业利润最大，市场份额占有率最高，进行税务筹划是我们的必由之路.1、企业追求股东财富最大化使税务筹划成为必然；企业要生存、发展、获利，盈得社会各界人士的好评，获得投资者最大额度的投资.追求股东财富最大化是他的根本目标。
实现该目标的途径总体来说有两条：一是增加企业收入，二是降低企业成本费用。
而税款就作为一项费用而存在，在收入不变的情况下,降低税务支出，就等于降低成本费用，从而实现股东财富最大化。
2、税法的规定性、法律的严肃性使税务筹划成为必然；所谓税务筹划，是指在投资、筹资、经营、股利分配等业务发生之前，在法律、法规允许的范围之内，事先对纳税事项进行安排，以达到最低纳税额度。
而一旦投资、筹资、经营、股利分配等事项已发生，那么纳税义务就已经产生，这时再想方设法少交税款，就成为偷税、漏税，必将受到法律处罚.合理、合法、合规、及时、有效地进行税务筹划就象一把双刃剑，一方面使企业遵纪守法；一方面降低企业成本费用,增加净利.最终达到增强企业活力，提高的社会效益和经济效益的目的。
论企业税收筹划的主要内容和方法
论企业税收筹划的主要内容和方法企业税收筹划是指企业通过合理利用税收政策和法律规定，调整企业经营活动，降低税收负担的一种行为。
它的主要内容包括税前利润管理、企业税收筹划的方式和方法。
首先，税前利润管理是企业税收筹划的重要内容之一、税前利润管理是指企业通过调整企业的经营行为和会计核算方法，使企业经营状况和会计信息与税收规定相匹配，从而降低纳税义务。
常见的税前利润管理手段包括业务结构的合理调整、资源配置的优化、费用的增加或减少等。
例如，企业可以通过合并、独立、分立等操作方式调整业务结构，以减少所得税支出。
另外，企业可以通过在费用核算上进行调整，例如增加研究开发费用、广告费用等，以降低应纳税所得额。
其次，企业税收筹划的方式和方法涉及多方面。
一是通过合理利用税收优惠政策降低税收负担。
为了促进经济发展，各国家普遍设立了一系列税收优惠政策，如减免企业税、投资补贴、税收抵免等。
企业可以通过申请享受这些政策，降低税收负担。
二是通过跨国税收筹划降低税收负担。
跨国企业在各国实行不同的税率和税制，可以通过合理调整母子公司的业务关系、利润分配方式等手段，实现在不同国家的税收优惠。
三是通过转移定价筹划降低税收负担。
企业通过在跨国间的内部交易中进行定价调整，以调整跨国利润的分配，实现税务优势。
这种方式需要企业在合规性和风险的平衡中进行。
另外，企业税收筹划的方法也具有一定的特点。
首先，要根据企业自身的情况开展税收筹划。
企业应当结合自身的行业特点、规模情况、经营模式等因素，制定适合自己的税收筹划方案。
其次，要准确掌握税收法律法规和政策的变化。
税收法律法规和政策是企业开展税收筹划的基础，企业需要密切关注税务部门发布的相关政策，及时进行调整和优化。
再次，要实施合法、合规的税收筹划。
企业在税收筹划中必须遵守国家的法律法规，不得采取不合法或不合规的手段，以避免不必要的风险和损失。
在进行企业税收筹划时，企业需要注意一些风险和问题。
首先，税收筹划的合法性与合规性需要得到明确证明。
税收筹划的基本方法
税收筹划的基本方法税收筹划是指通过合理利用税法规定和税收政策的手段，合法地降低纳税义务，提高企业效益的一种管理手段。
税收筹划对于企业来说是非常重要的，它可以帮助企业降低成本、提高竞争力、增加利润。
本文将介绍税收筹划的基本方法，帮助企业更好地实施税收筹划。
税收筹划的基本方法主要包括以下几个方面：1. 合理选择税务登记地点。
税务登记地点的选择可以影响企业的税收负担。
根据不同地区的税收政策、税率以及对企业的支持程度，选择合适的税务登记地可以实现最佳的税收筹划效果。
例如，一些地区对于新创办的企业提供税收优惠政策，合理选择税务登记地可以享受到更多的优惠。
2. 合理利用税法规定的减免税政策。
税法规定了许多减免税政策，企业可以通过合理利用这些政策降低纳税义务。
例如，企业可以通过资本化、折旧、研发费用等多种方式，合理调整利润结构，减少应纳税额。
此外，还可以积极申请各种减免税证书，享受相关税收优惠。
3. 整合资源，降低税务风险。
企业在进行税收筹划时，应整合各种资源，降低税务风险。
可以积极寻找专业的税务顾问，以确保税收筹划的合法性和可行性。
合理规划企业的财务结构，避免存在违规操作的风险，如虚假账目、偷漏税等行为。
4. 制定合理的跨国税收筹划方案。
对于跨国企业来说，制定合理的跨国税收筹划方案可以降低税收负担，提高企业效益。
可以通过设立海外分公司、转移定价等方式，合理分配利润，降低税务负担。
但是，企业应注意遵守国际税收规则和相关法律法规，避免涉及跨国税收逃避行为。
5. 合理运用税收调整工具。
税收调整工具是指通过合法的方式调整企业的税收负担。
例如，企业可以通过合理的资产配置，利用税收优惠政策来降低税负。
此外，还可以运用税收合规策略，及时了解并适应税法的变化，避免不必要的税务风险。
6. 定期进行税收审核和整改。
税收筹划不是一次性的工作，而是一个长期的过程。
企业应定期进行税收审核，了解企业的税收情况，及时发现存在的问题。
如果存在税收风险或不符合税法规定的问题，应及时进行整改，避免可能的税务处罚和纳税压力。
浅谈企业税收筹划的基本思路和方法
浅谈企业税收筹划的基本思路和方法企业税收筹划是指企业为了合理避免、减少或推迟税务负担，通过合法的手段进行的一种方法。
企业税收筹划的目的在于降低企业的税负，增加企业的利润，提高企业的竞争力。
基本的思路和方法如下：1. 合法合规：企业税收筹划的首要原则是遵循国家税收法律法规，在合法的范围内开展税务优惠活动。
企业不能采取违法手段进行虚假报表、漏报税款等行为。
2. 详细了解税收政策：企业需要对相关税收政策进行详细了解，包括各种税收优惠政策、减免条件等。
还要关注税收政策的动态变化，及时调整和优化自己的税收筹划方案。
3. 合理利用税收优惠政策：根据企业的经营性质和特点，合理利用各种税收优惠政策。
对于高新技术企业，可以申请享受高新技术企业税收优惠政策；对于小型微利企业，可以申请享受小型微利企业所得税优惠政策等。
4. 合理规划财务结构：企业可以通过调整财务结构，来降低税负。
合理运用债权和股权等财务工具，进行合理的财务安排，以降低企业的税负。
5. 优化收入结构：企业可以通过优化收入结构，合理安排营业成本、成本费用，从而降低企业的纳税基数。
通过合理安排成本费用的计提时间，可以推迟纳税时间，实现税收的推迟缴纳。
6. 合理运用税收减免项目：企业可以申请享受税收减免项目，以减轻税负。
合理利用税收抵免和退税政策，减少应纳税额。
7. 合理开展税务筹划活动：企业可以通过合理安排资金流动，优化企业的运作模式，开展税务筹划活动。
合理调整企业内部的交易定价，以优化税收规划。
8. 加强与税务部门的沟通协调：企业应该与税务部门保持良好的合作关系，加强沟通和协调。
通过与税务部门的互动，了解税务政策的最新动态，避免税务风险。
企业税收筹划是一个复杂的系统工程，需要企业全面、系统的考虑。
企业应该在遵循法律法规的基础上，通过合法合规的手段，合理利用税收优惠政策，优化自己的税收筹划方案，以降低税负，增加利润，提高企业的竞争力。
纳税筹划外文文献原文及翻译
Tax PlanningTax planning involves conceiving of and implementing various strategies in order to minimize the amount of taxes paid for given period. For a small business, minimizing the tax liability can provide money for expenses, investment, or growth. In this way, tax planning can be a source of working capital. According to The Entrepreneur Magazine Small Business Advisor, two basic rules apply to tax planning. First, a small business should never incur additional expense only to gain a tax deduction. While purchasing necessary equipment prior to the end of tax year can be a valuable tax planning strategy, marking unnecessary purchases is not recommended. Second a small business should always attempt to defer taxes when possible. Deferring taxes enables the business to use that money interest-free, and sometimes even earn interest on it, until the next time taxes are due.Experts recommend that entrepreneurs and small business owners conduct formal tax planning sessions in the middle of each tax year. This approach will give them time to apply their strategies to the current year as well as allow them to get a jump on the following year. It is important for small business owners to maintain a personal awareness of tax planning issues in order to save money. Even if employ a professional bookkeeper or accountant, small business owners should keep careful tabs on theirs own tax preparation in order to take advantage of all possible opportunities for deduction and tax savings.＂Whether or not you enlist the aid of an outsider, you should understand the basic provisions of the tax code.＂Just as you would not turn over the management of your money to another person, you should not blindly allow someone else to take complete charge of your tax paying responsibilities." In addition, as Frederick W. Dailey wrote in his book Tax Savvy for Small Business, "Tax knowledge has powerful profit potential. Knowing what the tax law has to offer can give you a far better bottom line than your competitors who don't bother to learn.General Areas of Tax PlanningThere are several general areas of tax planning that apply to all sorts of small businesses. These areas include the choice of accounting and inventory-valuation methods, the timing of equipment purchases, the spreading of business income among family members, and the selection of tax-favored benefit plans and investments. There are also some areas of tax planning that are specific to certain businessforms—i.e., sole proprietorships, partnerships, C corporations, and S corporations. Some of the general tax planning strategies are described below:ACCOUNTING METHODS.Accounting methods refer to the basic rules and guidelines under which businesses keep their financial records and prepare their financial reports. There are two main accounting methods used for record-keeping: the cash basis and the accrual basis. Small business owners must decide which method to use depending on the legal form of the business, its sales volume, whether it extends credit to customers, and the tax requirements set forth by the Internal Revenue Service (IRS). The choice of accounting method is an issue in tax planning, as it can affect the amount of taxes owed by a small business in a given year.Accounting records prepared using the cash basis recognize income and expenses according to real-time cash flow. Income is recorded upon receipt of funds, rather than based upon when it is actually earned, and expenses are recorded as they are paid, rather than as they are actually incurred. Under this accounting method, therefore, it is possible to defer taxable income by delaying billing so that payment is not received in the current year. Likewise, it is possible to accelerate expenses by paying them as soon as the bills are received, in advance of the due date. The cash method is simpler than the accrual method, it provides a more accurate picture of cash flow, and income is not subject to taxation until the money is actually received.In contrast, the accrual basis makes a greater effort to recognize income and expenses in the period to which they apply, regardless of whether or not money has changed hands. Under this system, revenue is recorded when it is earned, rather than when payment is received, and expenses recorded when they are incurred, rather than when payment is made. The main advantage of the accrual method is that it provides a more accurate picture of how a business is performing over the long-term than the cash method. The main disadvantages are that it is more complex than the cash basis, and that income taxes may be owed on revenue before payment is actually received. However, the accrual basis may yield favorable tax results for companies that have few receivables and large current liabilities.Under generally accepted accounting principles (GAAP), the accrual basis of accounting is required for all businesses that handle inventory, from small retailers to large manufacturers. It is also required for corporations and partnerships that have gross sales over $5 million per year, though there are exceptions for farmingbusinesses and qualified personal service corporations—such as doctors, lawyers, accountants, and consultants. Other businesses generally can decide which accounting method to use based on the relative tax savings it provides.INVENTORY VALUATION METHODS. The method a small business chooses for inventory valuation can also lead to substantial tax savings. Inventory valuation is important because businesses are required to reduce the amount they deduct for inventory purchases over the course of a year by the amount remaining in inventory at the end of the year. For example, a business that purchased $10,000 in inventory during the year but had $6,000 remaining in inventory at the end of the year could only count $4,000 as an expense for inventory purchases, even though the actual cash outlay was much larger. Valuing the remaining inventory differently could increase the amount deducted from income and thus reduce the amount of tax owed by the business.The tax law provides two possible methods for inventory valuation: the first-in, first-out method (FIFO); and the last-in, first-out method (LIFO). As the names suggest, these inventory methods differ in the assumption they make about the way items are sold from inventory. FIFO assumes that the items purchased the earliest are the first to be removed from inventory, while LIFO assumes that the items purchased most recently are the first to be removed from inventory. In this way, FIFO values the remaining inventory at the most current cost, while LIFO values the remaining inventory at the earliest cost paid that year.LIFO is generally the preferred inventory valuation method during times of rising costs. It places a lower value on the remaining inventory and a higher value on the cost of goods sold, thus reducing income and taxes. On the other hand, FIFO is generally preferred during periods of deflation or in industries where inventory can tend to lose its value rapidly, such as high technology. Companies are allowed to file Form 970 and switch from FIFO to LIFO at any time to take advantage of tax savings. However, they must then either wait ten years or get permission from the IRS to switch back to FIFO.EQUIPMENT PURCHASES. Under Section 179 of the Internal Revenue Code, businesses are allowed to deduct a total of $18,000 in equipment purchases during the year in which the purchases are made. Any purchases above this amount must be depreciated over several future tax periods. It is often advantageous for smallbusinesses to use this tax incentive to increase their deductions for business expenses, thus reducing their taxable income and their tax liability. Necessary equipment purchases up to the limit can be timed at year end and still be fully deductible for the year. This tax incentive also applies to personal property put into service for business use, with the exception of automobiles and real estate.WAGES PAID TO FAMILY MEMBERS. Self-employed persons can also reduce their tax burden by paying wages to a spouse or to dependent children. Wages paid to children under the age of 18 are not subject to FICA (Social Security and Medicare) taxes. Under normal circumstances, employers are required to withhold 7.65 percent of the first $62,700 of an employee's income for FICA taxes. Employers are also required to match the 7.65 percent contributed by every employee, so that the total FICA contribution is 15.3 percent. Self-employed persons are required to pay both the employer and employee portions of the FICA tax.But the FICA taxes are waived when the employee is a dependent child of the small business owner, saving the child and the parent 7.65 percent each. In addition, the child's wages are still considered a tax deductible business expense for the parent—thus reducing the parent's taxable income. Although the child must pay normal income taxes on the wages he or she receives, it is likely to be at a lower tax rate than the parent pays. Some business owners are able to further reduce their tax burden by paying wages to their spouse. If these wages bring the business owner's net income below $62,700—the threshold for FICA taxes—then they may reduce the self-employment tax owed by business owner. It is important to note, however, that the child or spouse must actually work for the business and that the wages must be reasonable for the work performed.BENEFITS PLANS AND INVESTMENTS. Tax planning also applies to various types of employee benefits that can provide a business with tax deductions, such as contributions to life insurance, health insurance, or retirement plans. As an added bonus, many such benefit programs are not considered taxable income for employees. Finally, tax planning applies to various types of investments that can shift tax liability to future periods, such as treasury bills, bank certificates, savings bonds, and deferred annuities. Companies can avoid paying taxes during the current period for income that is reinvested in such tax-deferred instruments.Tax Planning for Different Business Forms"The first step in tax planning—for small business owners and professionals, at least—is to select the right form of organization for your enterprise," according to Albert B. Ellentuck in the Laventhol and Horwath Small Business TaxPlanning Guide. "You'll end up paying radically different amounts of income tax depending on the form you select. And your odds of being audited by the IRS will change, too." Many aspects of tax planning are specific to certain business forms; some of these are discussed below:SOLE PROPRIETORSHIPS AND PARTNERSHIPS. Tax planning for sole proprietorships and partnerships is in many ways similar to tax planning for individuals. This is because the owners of businesses organized as sole proprietors and partnerships pay personal income tax rather than business income tax. These small business owners file an informational return for their business with the IRS, and then report any income taken from the business for personal use on their own personal tax return. No special taxes are imposed except for the self-employment tax (SECA), which requires all self-employed persons to pay both the employer and employee portions of the FICA tax, for a total of 15.3 percent.Since they do not receive an ordinary salary, the owners of sole proprietorships and partnerships are not required to withhold income taxes for themselves. Instead, they are required to estimate their total tax liability and remit it to the IRS in quarterly installments, using Form 1040 ES. It is important that the amount of tax paid in quarterly installments equal either the total amount owed during the previous year or 90 percent of their total current tax liability. Otherwise, the IRS may charge interest and impose a stiff penalty for underpayment of estimated taxes.Since the IRS calculates the amount owed quarterly, a large lump-sum payment in the fourth quarter will not enable a taxpayer to escape penalties. On the other hand, a significant increase in withholding in the fourth quarter may help, because tax that is withheld by an employer is considered to be paid evenly throughout the year no matter when it was withheld. This leads to a possible tax planning strategy for a self-employed person who falls behind in his or her estimated tax payments. By having an employed spouse increase his or her withholding, the self-employed person can make up for the deficiency and avoid a penalty. The IRS has also been known to waive underpayment penalties for people in special circumstances. For example, theymight waive the penalty for newly self-employed taxpayers who underpay their income taxes because they are making estimated tax payments for the first time.Another possible tax planning strategy applies to partnerships that anticipate a loss. At the end of each tax year, partnerships file the informational Form 1065 (Partnership Statement of Income) with the IRS, and then report the amount of income that accrued to each partner on Schedule K1. This income can be divided in any number of ways, depending on the nature of the partnership agreement. In this way, it is possible to pass all of a partnership's early losses to one partner in order to maximize his or her tax advantages.What’s more, enterprises to carry out the correct tax, the need for the adoption of the following major route of transmission.First, reasonable means of financing options. In accordance with the provisions of China's current tax law, corporate interest payments on the loan within a certain range can be pre-tax expenses, and dividends can only be spending the after-tax profits of enterprise expenses. From a tax point of view, appropriate to the bank business loans and financing between enterprises, rather than directly to the fund-raising benefits.Second, a reasonable choice of trading partners. China's existing value-added tax system has a general taxpayers and small-scale taxpayers on the points, choose a different supplier object, the tax burden on enterprises is not the same. For example, when the Department of suppliers of value-added tax general taxpayer, the business after the purchase of goods, according to the amount of tax deduction of input tax amount of the corresponding balance after payment of value-added tax; if the purchase of goods for small-scale taxpayers, VAT can not be achieved Its not contain the amount of input tax deduction, the tax burden more than the former. Such as open invoices can also be part of deduction.Third, "the easy way out" tax conversion. Enterprises will be converted to high-tax low-tax, refers to economic activities in the same, there are a variety of revenue options to choose from, the taxpayers to avoid "high-tax point", choose the "low tax" and reduce the tax liability . The most typical example of this is to run non-taxable to the tax planning services. From the tax point of view, run mainly two: First, the same taxes, different tax rates. Systems such as supply and marketing enterprises, the general operating tax rate is 17% of the means of subsistence, but also the operatingvalue-added tax rate of 13% of the agricultural means of production and so on. Second, different taxes, different tax rates. This usually refers to types of enterprises in their business activities, both value-added business project, the project also involves the business tax.Fourth, the cost of reasonable expenses. Enterprises does not violate tax laws and financial system under the premise of the full cost of the reasonable expenses, that may occur on the full estimated losses and narrow the tax base and reduce the amount of taxable income. Countries allow for costs incurred in the projects, such as wages, respectively, the total amount of tax by 2%, 14%, 1.5% extracts of trade union funds, staff welfare, staff education funding should be sufficient to mention as much as possible to the whole. For some of the losses that may occur, such as bad debt losses, businesses should be fully expected in the tax law as far as possible the extent permitted by the cap enough to reserve. This is in line with the national tax law and financial system, can receive the tax effect.Fifth, to reduce tax liability. Factors that affect the tax liability there are two, namely, tax base and tax rates, the smaller the tax base, lower tax rates, tax liability is also smaller. Tax planning can start from these two factors to find legitimate ways to reduce tax liability. For example, an enterprise December 30, 2005 estimated taxable income amounted to 100,200 yuan, the enterprise income tax liability 25050 yuan (100200 ×25%). If the corporate tax planning, tax consulting fees to pay 200 yuan, the corporate taxable income 100,000 (100200-200), income tax liability 27,000 yuan (100000 × 27%), can be found by comparing, for tax planning to pay only 200 yuan, 6066 yuan tax is (33066-27000).Sixth, to weigh the severity of the overall tax burden. For example, many value-added tax planning programs have the general taxpayer and the taxpayer to choose small-scale planning. If an enterprise is a non-tax-year sales of about 900,000 yuan of production enterprises and enterprises to buy the materials each year the price of non-value-added tax of 70 million or less. The company's accounting system, the conditions identified as the general taxpayers. If that is the general taxpayer, the company's products are value-added tax rate applies to 17% capital gains tax liability 34,000 yuan (90 × 17% -70 × 17%); If it is small-scale taxpayers, the rate is 6%, 5.4 VAT liability million (90 ×6%)> 3.4 million. Therefore, from the perspective of value-added tax general taxpayer should be selected. But, in fact, although small-scaleVAT taxpayers pay 20,000 yuan, but the input tax amount of 119,000 yuan (70 ×17%), although it can not offset the costs, thereby increasing the cost of 119,000 yuan, the income tax reduction of 2.975 million (11.9 × 25%), than pay a 20,000 yuan of value-added tax. Therefore, the business tax planning in the selection of programs, not only to look in a certain period of time watching the program on tax less, and to consider business development goals, to choose to increase their overall revenue program.Seventh, take full advantage of preferential taxation policies. For taxpayers, the use of tax incentives for tax planning focuses on how the rational use of tax policies and regulations shall apply to the lower or more favorable tax rates, a well-planned production and operation activities, the actual tax burden to a minimum in order to achieve Festival tax effect. For example, according to China's Law of the State Council for approval of high-tech industrial development zone of the high-tech enterprises, since the production from the fiscal year income tax exemption for 2 years. To-business use of wastewater, waste gas, waste residue and other waste as the main raw materials for production, 5 years in the income tax reduction or exemption. In addition, to support agriculture and the development of UNESCO Wei investment, countries have different tax incentives. Business operators should refer to policy, comparing the investment environment, investment income, investment risks and other factors, decided to invest in the region, investment direction, as well as investment projects, a reasonable tax planning, in order to reduce the corporate tax burden.It should be noted that the above-mentioned methods taxpayers use tax, on the one hand, it is necessary to comply with the characteristics of enterprise production and management, overall planning, comprehensive consideration and can not cater for all kinds; On the other hand, to keep learning and understanding of national trends and policies on tax reform measures amendments and adjustments, accurately grasp the limits of tax regulations and policies, in-depth study of the relevant provisions of tax laws to prevent tax and give rise to other problems.税收筹划税收筹划涉及的设想和实施各种策略的目的是尽量减少对一定时期内支付的税款。
税收筹划的外文文献及翻译
Planning forever tax savings●Learn how to keep your tax bill at the legal minimum…and keep it there!By Mark E.BattersbyNow is the best time to think about reducing the ornamental and miscellaneous metal operation’s tax bill even lower than the point the economy may have driven it to.And,of course,aim to keep that tax bill at its legal minimum for many year to come.While many of us rely on the advice and help provided by tax professionals or utilize software programs to ensure a low tax bill,the real goal should be a low tax bill for not just this tax year but year-after-year.The best guarantee of consistently low tax bill,this year,next year,and so-on down the road is,of course,tax planning.Tax planning is easy:the more tax deductions taken,the lower the fabricating operations taxable income will be----at least for this tax year.Of course,ignoring potential tax deductions this year might mean significant savings in later years when profits----and tax bills---are higher.Either way,in order for deductions to count,the time to make the moves necessary for those low tax bills is before the end of the tax year.Tax Planning BasicsWhen thinking about any type of tax planning,every metal fabricator should keep in mind that although the IRS may occasionally disagree,the courts strongly back every taxpayer’s right to choose the course of action that will result in the lowest legal tax liability.Thus,as the end of the tax year quickly approaches,every fabricator faces several different options as to how to complete certain taxable transactions.Out tax system has graduated rates that increase along with the income of the metal fabrication business at various tax rates.Thus,one strategy for saving taxes means reducing the tax bracket of the fabricating operation.Getting the most from the temporary 15-percent tax rate for dividends,means finding another way to reduce corporate level income----and taxes?Obviously,neither an ornamental metal fabricating business nor any business owner can literally reduce their federal income tax rate.They can however,take actions that will have a similar effect.For example:●Choosing the optimal from of organization for the business(such as soleproprietorship,partnership,corporation or S Corporation).Although not ayear-end tax planning strategy,this option deserves attention in the overall taxplanning process especially in light of the current,and temporary,15 percenttax rate on dividends paid by incorporated metalworking businesses.●Structuring transactions so that payments received are capitalgains.Long-term capital gains earned by non-corporate taxpayers are subjectto lower tax rates than other income.●Shifting income from a high-tax bracket individual(such as you,the businessowner),to a lower-bracket individual(such as your child).One fairly,simpleway to accomplish this is by hiring your children.Another possibility is tomake one or more children partners in the business,so that net profits areshared among a larger group.While the tax laws limit the usefulness of this srtategy for shifting “unearned”income to children under the age of 14,some opportunities to lower tax rates still do exist.Remember,however,the time to think about those strategies is during the course of the tax year.Consistently ConsistentAlthough the goal is usually to reduce taxes this year,to be really effective the tax bracket should be consistent year-after-year.If income is up this year but expected to be down next year,for instance,an ornamental metal business might want to postpone asset sales or other unusual transactions until next year when the additional profits may not be as likely to put the operation into a higher tax bracket.Or,conversely if income and profits are down this year,disposing of unneeded equipment or business assets via a profitable sale just might generate extra income,income taxed at the operation’s current low tax rates.Depending on the circumstances,a number of legitimate strategies a metal fabricating business can employ before year’s end will help them remain in the same bracket this year,next year,and for many year thereafter.Those basic year-end savings strategies include:●Delaying Collections:A cash basis metal fabricating operation can delayyear-end billings until late enough in the year so payments will not come inuntil the following year.●Accelerate Payments:Wherever possible, prepay deductible businessexpenses,including rent,interest,taxes,insurance,etc.Also,keep in mind thatthe tax rules limit tax deductions for some prepaid expenses.●Accelerate Large Purchases:Close the purchase of depreciable personalproperty or real estate within the current year.●Accelerate Operating Expenses:If possible,accelerate the purchase ofsupplies or services or the making of repairs.●Accelerate Depreciation:Elect to expense or immediately write-off the costof new equipment instead of depreciating it.Remember,the new Section 179tax rules now permit every metal fabricator to deduct,as an expense,up to$250,000 in expenditures for new equipment.Naturally,what a particular business can do depends a great deal on the accounting method used by the operation.A cash basis metal fabricating operation,for example,deducts expenses as paid and receipts become income when received----or made available.An accrual-basis business realizes income when billed and expenses when incurred----regardless of when income is actually,received,or when payment is made.This year’s law changesThe American Recovery and Reinvestment Act (ARRA) earlier this yearextended a number of expiring provisions and created a few more that will affect the year-end planning process.For example:●First-year 50% bonus depreciaton:ARRA extended the 50% bonus first-yeardepreciation allowance available for 2008 for 2009.●Increased Section 179 expensing:During 2009,ornamental metal businessescan choose to expenses and immediately deduct up to $250,000 of the cost ofqualifying property and equipment.The $250,000 maximum expensingamount is reduced if the cost of all Section 179 property placed in service in2009 exceeds $800,000.●S corporation built-in gains holding period.For tax years beginning in either2009 or 2010,ARRA eliminates the corporate level tax on the built-in gainsof an S corporation that converted from regular‘C’corporation status atleast seven tax years before the current tax year.Going,going,goneMaking year-end planning more urgent than usual,a number of provisions in our tax law expire in 2009.Among the expiring provisions are:●The tax credit for research and experimentation expenses.●Increased alternative minimum tax (AMT) exemption amounts.●15-year straight-line cost recovery for qualified leasehold improvements,qualifiedrestaurant buildings and improvements,and qualified retail improvements.●Additional first-year depreciation for 50% of basis of qualified property.●Increase in expensing to $250,000/$800,000.●Expensing of “Brownfield’s”environmental remediation costs.●Empowerment zone tax incentives.●Tax incentives for investment in the District of Columbia.●Renewal community tax incentives.●The FUTA surtax of 0.2 percent.●Sixty-five percent subsidy for payment of COBRA health care coveragecontinuation premiums.●Reduced estimated tax payments for small businesses.●Use of single-employer defined benefit plan’s prior year adjusted fundingtarget attainment percentage to determine application of limitation on benefitaccruals.Tax tail should not wag the dogThere is a great deal of pressure in many metal fabricating businesses to continue cutting costs,including taxes.This coincides with increased scrutiny of tax returns on many levels of government.Identifying opportunities for tax deductions without running afoul of cash-strapped,state and local tax authorities should play a role in the planning process.On a similar note,the financial or operational strengths of a business transaction should always stand on their own,aside from any tax benefits derived from them.There is also the question of whether a tax deduction should be taken or iflegally,feasible,ignored.An excellent illustration of the flexibility of our tax rules are those governing bonuses.A metal fabricating business operating on the accrual basis has the opportunity to fix the amount of employees’ bonus payments before January 1 --- but to pay them early next year.Generally,the bonuses are not taxable to employees until 2010,but are deductible on the operation’s 2009 tax return –so long as announced before the end of 2009,and paid before March 16,2010.On the other hand,while few businesses are in a position to pay employee bonuses,an ornamental and miscellaneous metalbusiness may benefit by delaying income until next year.Remember,however,there is constructive receipt when income is made available to the fabricating business.Tax planning all the timeAlthough tax planning should be a year-round process,a number of year-end strategies can reduce not only this year’s tax bill,but future tax bills as well.The owners and managers of every metal fabrication business should also be taking additional steps to ensure the success of the operation in 2010.Whether or not the metalworking operation is facing a large tax bill or severely lower taxable income,professional advice is almost a necessity.There should however,be no uncertainty regarding the need for planning to minimize taxes this year as well as in future tax years.For your informationThe goal:You should always strive to keep your tax bill at the absolute minimum.The key is good tax planning,and looking at what decision work best in the long-run.For instance,sometimes it’s better to ignore a potential tax deduction one year to save more in a later year when tax bills are higher.Optimize your company:Do you have the best structure for your company,such as a partnership,proprietorship,or S corporation?Other tips:Have you structured transactions so that payments received are capital gains?Can you shift income from a high-tax bracket individual,such as yourself,to a lower-bracket individual,such as a child?One way to accomplish this is to hire your children or make them a partner in the business, which allows the next profits to be shared among a larger group.While the tax laws limit the shifting “unearned”income to children under age of 14,some opportunities do exist.永久节税筹划■学会怎样在合法范围内将税额减少到最低并一直保持下去现在是考虑降低金属饰品和五金经营税额的最好时机，因为那甚至可以比自然经济趋势下所能达到的税额更低。
税收筹划的方法有哪些？
税收筹划的方法有哪些？税收筹划的方法有哪些法律分析：企业纳税筹划有以下方法：1、利用税收优惠政策进行税收筹划，选择投资区域和产业。
2、合理利用企业组织形式进行税收筹划。
3、充分利用税法和税务文书的规定。
运用这种方法进行税收筹划，要求企业充分了解国家税收政策。
4、充分利用财务会计制度，转移税收负担。
5、税务筹划是利用开支扣除准则的选择来进行的。
税收优惠政策是指国家鼓励发展某些行业、地区和产品，在税收方面对资源配置作出特殊优惠规定。
法律依据：《中华人民共和国税收征收管理法》第一条为了加强税收征收管理，规范税收征收和缴纳行为，保障国家税收收入，保护纳税人的合法权益，促进经济和社会发展，制定本法。
第二条凡依法由税务机关征收的各种税收的征收管理，均适用本法。
第三条税收的开征、停征以及减税、免税、退税、补税，依照法律的规定执行;法律授权国务院规定的，依照国务院制定的行政法规的规定执行。
任何机关、单位和个人不得违反法律、行政法规的规定，擅自作出税收开征、停征以及减税、免税、退税、补税和其他同税收法律、行政法规相抵触的决定。
第四条法律、行政法规规定负有纳税义务的单位和个人为纳税人。
法律、行政法规规定负有代扣代缴、代收代缴税款义务的单位和个人为扣缴义务人。
纳税人、扣缴义务人必须依照法律、行政法规的规定缴纳税款、代扣代缴、代收代缴税款。
税务筹划的基本步骤税务筹划是指在遵行税收法律法规的前提下，当存在两个或两个以上纳税方案时，为实现最小合理纳税而进行设计和运筹。
税务筹划的实质是依法合理纳税，并最大程度地降低纳税风险，尽可能的减少应缴税款的一种合法经济行为。
(一)收集税收筹划必需的信息1、企业涉税情况与需求分析。
不同企业的基本情况及纳税要求有所不同，在实施税收筹划活动时，首先要了解企业以下基本情况：企业组织形式、筹划主体的意图、经营状况、财务状况、投资意向、管理层对风险的态度、企业的需求和目标等等。
其中，筹划主体的意图是税收筹划中最根本的部分，是税收筹划活动的出发点。
税收筹划的主要方法
税收筹划的主要方法
1. 合理利用税收优惠政策，各国都有不同的税收优惠政策，如
减免税、税收抵免、税收减免等。
纳税人可以通过合理规划财务活动，利用这些政策来降低纳税负担。
2. 合理安排资产结构，通过合理安排资产结构，包括资产配置、资产负债比例等，可以有效降低纳税人的应纳税额。
3. 利用税收避免合法漏洞，税法往往存在一些模糊地带或漏洞，纳税人可以通过寻找这些合法漏洞来降低应纳税款。
4. 跨境税收筹划，对于跨境企业来说，可以通过跨境税收筹划
来合理规避双重征税，降低跨境交易的税负。
5. 合理规划企业税务结构，企业可以通过重组、合并、分立等
方式来合理规划企业税务结构，降低企业整体税负。
然而，需要强调的是，税收筹划应当合法合规，不得违反税法
规定，否则将面临法律风险和处罚。
税收筹划应当在法律允许的范
围内进行，遵守税法，不得违法逃税。
税收筹划的目的是合理降低
纳税负担，而不是逃避纳税责任。
因此，纳税人在进行税收筹划时，应当谨慎合理，遵守法律法规，避免违法风险。
外文翻译---企业税收筹划的主要途径
外文翻译---企业税收筹划的主要途径企业税收筹划的主要途径纳税筹划是在严格执行税法的前提下，尽量减少缴税的方法，通常称为节税。
为正确地进行节税，企业需要采取以下主要途径。
一、选择合理的筹资方式。
根据我国现行税法规定，企业的借款利息支出在一定范围内可以税前列支，而股息支出则只能在企业的税后利润中列支。
从节税的角度来看，企业适度向银行借款和企业间的相互融资，比企业直接向社会筹资更优惠。
二、选择合理的交易对象。
我国现行增值税制度规定有一般纳税人和小规模纳税人之分，选择不同的供货对象，企业所负担的税负则不同。
例如，当供货方是增值税一般纳税人时，企业购进货物后，可按销项税额抵扣相应的进项税额后的余额缴纳增值税；如果购买小规模纳税人的货物，不能取得增值税专用的，其含有进项税额不能抵扣，税负比前者要多。
开专用也可抵扣一部分。
三、转换纳税义务，避重就轻。
企业将高纳税义务转换为低纳税义务是指在同一经济行为中，有多种税收方案可供选择时，纳税人避开“高税点”，选择“低税点”，可减轻纳税义务。
最典型的例子就是对兼营非应税劳务进行的节税筹划。
从税收角度来看，兼营主要包括两种：一是税种相同，税率不同。
例如供销系统企业，一般既经营增值税率为17%的生活资料，又经营增值税率为13%的农用生产资料等。
二是不同税种，不同税率。
该种类型通常是指企业在其经营活动中，既经营增值税项目，又涉及营业税项目。
四、合理列支各项费用。
企业可以在不违反税法和财务制度的前提下，通过对各项费用充分合理的列支，对各项可能发生的损失进行充分估计，缩小税基，减少应纳税所得额。
对于国家允许在费用中列支的项目，如分别按计税工资总额的2%、14%、1.5%提取的职工工会经费、职工福利费、职工教育经费，应尽可能地提足提全。
对于一些可能发生的损失，如坏账损失等，企业应充分预计，在税法允许的范围内尽可能按上限提足准备金。
这既符合国家税法和财务制度的规定，又能收到节税的效果。
税务筹划的主要方法
税务筹划的主要方法Tax planning is an essential aspect of financial management for individuals and businesses alike. It involves taking proactive steps to minimize tax liabilities within the confines of the law, ensuring compliance while maximizing savings. Tax planning can encompass various strategies, such as income deferral, tax credits, deductions, and legal loopholes, all aimed at reducing the tax burden imposedby government authorities. Effective tax planning requires a thorough understanding of tax laws, regulations, and changes that may impact one's financial situation.税务筹划是个人和企业财务管理中的一个重要方面。
它涉及采取积极措施，在法律限制范围内最大限度地减少税负，确保遵守法规同时最大化储蓄。
税务筹划可以涵盖各种策略，如收入推迟、税收抵免、扣除和法律漏洞，所有这些都旨在减少政府机构征收的税收负担。
有效的税务筹划需要对税法、法规和可能影响财务状况的变化有深刻的了解。
One of the main methods of tax planning is income deferral, which involves delaying the receipt of income to a later tax year. By postponing the recognition of income, individuals and businessescan potentially lower their current tax liabilities, benefiting from a lower tax rate in the future. This strategy is particularly useful for those expecting a decrease in income in the following year or anticipating changes in tax regulations that may reduce the tax burden. However, income deferral should be approached cautiouslyto ensure compliance with tax laws and regulations.税务筹划的主要方法之一是收入推迟，这涉及将收入推迟至以后的税收年度。
企业所得税税务筹划的途径
企业所得税税务筹划的途径税务筹划是在法律许可的范围内合理降低纳税人税负的经济行为。
税务筹划作为一项“双向选择”，不仅要求纳税人依法缴纳税款以及履行税收义务，而且要求税务机关严格“依法治税”。
税务筹划在减轻税收负担、获取资金时间价值、实现涉税零风险、追求经济效益最大化和维护自身合法权益等方面具有重要意义。
我国2008年新的企业所得税法在纳税人身份认定、税收优惠政策、税前扣除项目以及资产税务处理等方面进行了修订。
面对新的税法环境，纳税人要充分考虑和利用新法特点开展企业所得税税务筹划。
一、合理利用企业的组织形式开展税务筹划企业所得税法合并后，遵循国际惯例将企业所得税以法人作为界定纳税人的标准，原内资企业所得税独立核算的标准不再适用，同时规定不具有法人资格的分支机构应汇总到总机构统一纳税。
不同的组织形式分别使用独立纳税和汇总纳税，会对总机构的税收负担产生影响。
企业可以利用新的规定，通过选择分支机构的组织形式进行有效的税务筹划。
企业从组织形式上有子公司和分公司两种选择。
其中，子公司是具有独立法人资格，能够承担民事法律责任与义务的实体；而分公司是不具有独立法人资格，需要由总公司承担法律责任与义务的实体。
企业采取何种组织形式需要考虑的因素主要包括：分支机构盈亏、分支机构是否享受优惠税率等。
选择方案具体见表1。
（见附表）第一种情况：预计适用优惠税率的分支机构盈利，选择子公司形式，单独纳税。
第二种情况：预计适用非优惠税率的分支机构盈利，选择分公司形式，汇总到总公司纳税，以弥补总公司或其他分公司的亏损；即使下属公司均盈利，此时汇总纳税虽无节税效应，但可降低企业的办税成本，提高管理效率。
第三种情况：预计适用非优惠税率的分支机构亏损，选择分公司形式，汇总纳税可以用其他分公司或总公司利润弥补亏损。
第四种情况：预计适用优惠税率的分支机构亏损，这种情况下就要考虑分支机构扭亏的能力，若短期内可以扭亏宜采用子公司形式，否则宜采用分公司形式，这与企业经营策划有紧密关联。
跨国公司的税收筹划【外文翻译】
本科毕业论文（设计）外文翻译原文：A Framework for International Tax Planning for ManagersCreating a balance between minimizing all of the applicable taxes subject to additional constraints requires a tax planning framework which recognizes the coordination of legal methods to minimize taxes. Leitch and Barrett (1992) assert that a multinational firm exists to exploit a variety of advantages which occur due to differentials in ownership, location, and internationalization factors across country boundaries. These same sorts of advantages can be considered related to tax minimization. The multinational manager in the hypothetical firm of Global Co. must consider tax planning strategies subject to differences in: (1) jurisdiction; (2) time periods; (3) entities; (4) contractual forms; and (5) activities.JurisdictionIn a regulatory sense, taxation exists to accomplish a variety of societal objectives. Consequently, these objectives are manifested in differing tax rates and schemes among nations. Some nations offer a tax holiday to corporate entities to stimulate local investment and employment, while others offer no incentives. Similarly, allowable exclusions and deductions used in determining taxable income may differ among countries. Global Co. must consider all of these elements when selecting countries for operations. The multinational firm is in a position to exploit these differences to legally avoid taxes and minimize the overall tax burden. Complications arise when managers make tax policy decisions in isolation from the overall business needs of the firm. The optimal strategy includes international tax policy in conjunction with business strategy.’ If Global Co.selects countries for operating activities solely for tax considerations, then the firm may fail to derive the maximum benefit from a multinational strategy which seeks to exploit a variety of advantages.Time PeriodsSince the multinational firm often produces goods or services in a variety of places over different economic cycles, there are choices available which allow the firm to defer payment of tax or recognition of taxable income. The objective of this sort of planning is to allow income to be taxed at the lowest possible rate. For example, Global Co. might vary production schedules at locations in different countries to take advantage of differing tax rates. The cross-jurisdictional differences in effective tax rates for a multinational enterprise may change over time. During low points in a business cycle, an entity in one country may have net operating losses which result in a net income tax rate of zero. If that entity is unable to immediately apply the net operating losses, then the parent firm’s strategy might be to shift income into that country to take advantage of the net operating losses. The parent could shift income by raising the transfer prices paid on products from that country, or by reducing the royalty payments that the subsidiary .pays to other entities. Accelerating recognition of taxable income could also be advantageous if a firm expects favorable tax incentives will be expiring in the next year. During high points in a business cycle, the multinational enterprise could attempt to defer recognizing income in high-tax countries. For example, installment sales contracts could be written to defer income recognition to future periods. The sales contract could be revised to lower the price on initial purchases, and increase the price on future maintenance and upgrades. They could accelerate expense recognition by performing more currently deductible maintenance than constructing facilities that must be depreciated over long time periods.Choice of EntityThe multinational may select a variety of organizational forms with which to conduct transactions with distributed units in other countries. This choice has legal as well as tax implications for the combined entity. If foreign units are organized as subsidiaries, the parent may be allowed to defer recognition of income from the subsidiary until dividends are distributed to the parent. Organizing units as branches will result in the inclusion of all branch income in the worldwide income of the parent.In some countries, the parent may elect to form partnerships where any income or loss will flow directly through to the partners without taxing the foreign entity. A hybrid entity also may be formed which results in one jurisdiction taxing the unit as a partnership and another as a corporation. These choices will affect Global Co. in characterizing the income received in the venture as active, passive, or triggering capital gains. Each result yields differing tax effects. In any event, the choice of entity from a tax planning perspective must be balanced with the needs of the firm overall. Tax regulations are rather fluid, and the multinational must be prepared to face changing situations over time. More importantly, it may be difficult to change the organizational form of a foreign unit once established. Global Co. would need to evaluate the business purpose for a particular choice of entity in conjunction with the related tax effects to determine the optimal arrangement. Particular legal considerations may be so acute that Global Co. would elect to form a type of entity even if it resulted in less tax benefit.Contractual FormsVarious contractual forms for the structure and workings of the entity can affect the tax situation of the multinational. One of the fundamental choices for Global Co. is how to finance the foreign entity. Sekely and Collins (1988) show that the capital structure choice of a firm is influenced by the country location. Financing through debt or equity will have different tax effects related to the deductibility of interest expense and lack of deductibility for equity contributions. Similarly, interest income would be recognized as income to the recipient, whereequity received is generally not taxed as income. Convertible or hybrid securities may be considered as debt or equity for the multinational, depending upon the circumstances.Operational choices, such as whether to hire personnel as contractual employees or independent contractors, will also have different tax effects for Global Co. A similar situation exists with respect to owning or leasing various assets. Tax differentials among countries may exist requiring the multinational to balance these choices across foreign units.Corporate ActivitiesPerhaps the most logical, yet less direct, concern for tax planning involves an evaluation of the various activities undertaken by the multinational.Figure 1 provides a diagram of the activities of a U.S. parent corporation and its foreign subsidiary. For example, Global Co. might provide assistance to a foreign subsidiary in the form of research and development, financing, production, and marketing and distribution. When Global Co. (the parent) provides technology, the subsidiary pays the parent in the form of royalites or management fees which are taxable income to the parent and deductible by the subsidiary. The parent may provide oversight to the subsidiary in production decisions without creating a taxable event. Marketing and distribution activities may generate gains for either the parent or the subsidiary depending upon where title passes for the goods. Similarly, any transfers and the location of the sale of goods also affects value-added taxes and tariffs.In terms of financing, the taxation situation for Global Co. depends upon whether debt or equity was used to assist the subsidiary. Equity in foreign subsidiaries generates dividends or capital gains which are taxable to the parent by the full amount of the distribution.To minimize taxes for the combined corporate entity, taxation and source of income issues must be considered in all phases of Global Co.‘s activities. Particular activities may be desirable from a business perspective, but create less than ideal tax implications. For example, Global Co. may wish to exercise control over a subsidiary in the form of a significant equity interest, but may prefer merely to loan funds and generate taxable interest on the loan repayment in the very distant future. The rules for sourcing income of the combined enterprises in the U.S. or foreign countries are summarized in Table 3.The type of goods or services offered may influence the location of taxation of the transaction, and thus the eventual effective tax rate of the muItinational entity and any foreign subsidiaries. For example, if Global Co. exports inventory it purchased in the U.S. and title passes in Country X, then the income on that sale is classified as foreign-source income and any contract disputes would be determined under country X’s laws. To shift the sourcing of income on the sale of purchased inventories fromCountry X to the U.S., Global Co. could restructure its marketing so that title passes to the purchasers in the U.S. When a corporation manufactures goods in one country and exports them to its foreign branch, the income from the sale of those goods must be allocated between U.S.- and foreign-source income. If an arm’s_length transfer price can be estimated, then that transfer price is used to source income between the countries. If not, the gross income is classified as U.S. or foreign source using an appo~ionment formula based on the ratio of the firm’s property and sales in the U.S. and foreign countries. Passive investment income (interest and dividends from unrelated firms) is often subject to a type of withholding tax when the income is transferred out of the country. Capital gains on property are taxed according to the type of property. Tangible property gains typically are taxed in the country where the property is located. Gains on intangible property may be taxed in the country where the owner of the intangible property resides. This result may make it necessary for Global Co. to consider the ownership of any intangible property that the foreign entity may require for operations.Once Global Co. determines the appropriate tax strategy given an overall business strategy, compliance is the next phase which confronts the manager with a set of choices. The results of a U.S.-based multinational firm’s efforts at tax minimization on a global scale are first apparent in calculations on the U.S. income tax return. For foreign income taxes paid, the taxpayer may select each year either a deduction to reduce taxable income or a foreign tax credit that directly reduces the tax liability. For taxes paid other than income, deduction is the only treatment allowed. For Global Co., the optimal choice between a tax deduction or tax credit will depend upon the type of income created by the specific foreign entity and related types of worldwide income generated by the combined entity. Choices that Global Co. made previously with regard to the type of entity, financing decisions, location of foreign operations, and passing of title, etc. for the foreign entity will be reflected in the type and character of income generated by the foreign entity.While multinationals attempt to create a tax policy which minimizes total taxes and maximizes after-tax cash flow, the governments who administer tax regulationalso pursue their own goals. These governments try to maximize their own social policy goals given a variety of constraints and external factors. Multinationals can improve their own tax planning by evaluating the position of foreign governments with respect to their own tax policy objectives and future changes. Therefore, for planning purposes, the multinational should evaluate tax policy goals of foreign governments and method of collection for each country where the firm maintains operations.In achieving their revenue goals, governments may adjust either the tax rate or the tax base, or attempt to stimulate total economic output through incentives. Employment goals for the workforce provide incentives for firms to support job growth in particular regions, or to expand specific targeted industries. Govemments could also seek to create a neutral environment which mitigates incentives for firms to adjust their business behavior solely in response to tax differences. This type of consideration is also reflected in allowing credit for taxes paid to foreign governments to avoid double taxation for multinationals. Cooperation between the governments of nations is evidenced by the creation of multilateral trade treaties and bilateral tax treaties. These agreements greatly simplify compliance and minimize uncertainty for multinationals. Another aspect which will affect the tax policy of multinationals is the tax administrative process in each country. Transactions in the U.S. are characterized by a set of formal rules, while negotiated settlements are much more common in countries such as the Netherlands. At present, relative instability in the administrative process in the former Soviet Union greatly complicates tax planning for multinationals with operations there.Most countries employ a mix of several methods to execute their tax policy. Taxable income can be calculated using worldwide or territorial income. The relative effects of such policies on a multinational depend upon specific calculations for income according to source. Non-resident corporations may also be subject to a withholding tax on income earned.For Global Co., an optimal international tax minimization strategy has involved the use of subsidiaries in tax haven countries, FSCs, transfer pricing, income sourcingand characterization decisions affecting active and passive distinctions, and the creation of a financing subsidiary. All of these decisions were made in conjunction with the overall global strategy of the company and the motivations for creating a multinational entity. Tax considerations outside of the U.S. were balanced with legal, political and economic risks. Ultimately, Global Co.‘s strategy incorporates these risks and evaluates competitive situations to choose the appropriate form of entity and location. Financing and operational decisions would seek to minimize taxes, but not to the detriment of the overall strategic purpose in creating foreign operations.The central theme of this paper is that multinational firms can use a variety of techniques to reduce or defer payment of income taxes. In developing strategies to maximize after-tax cash flow, both tax and non-tax factors must be considered. Sometimes the tax benefits of implementing a particular tax-minimizing strategy are less than the non-tax costs. Previous sections of this paper have shown basic concepts and examples of the international tax implications of the choice of jurisdiction, timing, entity form, contractual form, and activities. Although the legal details are complex, all managers in multinational firms should be aware of the basic concepts of international taxation that have implications for operational and financing choices. Table 8 provides a summary of the major operational and organizational issues facing the multinational firm, along with related international tax issues. It is critical to consider how the entire corporate entity is affected by the collective impact of a variety of business decisions with differing tax treatments.Source: William F.Yancey,1998.“A Framework for International Tax Planning for Manager ”.Auditing&Taxation.July,pp.252-272.译文：跨国公司的税收筹划在最少化所有的应纳税款和他们的约束条件之间达到平衡，依靠一个合法的税收筹划框架，以减少税收。
税务筹划外文文献翻译
税务筹划税务筹划是指通过筹划各种方法和策略以减少在一定时期内支付的税款。
对于一家小公司来说，尽量减少税务负担可以有更多机会投资去赚更多的钱。
这样，税务筹划可以说是公司的资金来源的一部分。
根据企业家杂志顾问，税务筹划适用于两个基本规则。
首先，小企业不应承担额外开支只为了得到税收减免。
在购买必要的设备之前，应该有一个有价值的税收计划避免产生一些不必要的费用。
第二，小公司总是试图尽可能推迟纳税。
推迟纳税使该公司能够利用这些钱免息，有时甚至是赚取利息税，直到下一次税款到期。
专家建议，大企业家和小企业主在每一年度中间开统筹会进行税务筹划。
这种做法将让他们有时间运用税务策略同时获得来年的跳跃。
对于小型企业来说，认识到税务统筹的重要性有利于节约资金。
即使他们聘请专业的会计和会计师，小企业主也应该谨慎制表，以便有更多的机会减免税收。
艾伯特在小型企业家指南中写到：“无论你是否获得一个局外人的帮助，你都应该了解税法的基本规定”。
“正如你不会把你的钱交给另一个人去管理一样，你不应该盲目地让别人去掌控你的税收。
”另外，正像弗雷德里克W ·戴利在他的《小企业家节税》中写的：“税务筹划具有强大的盈利潜力。
了解和掌握税收筹划带给你的要比不去学习税法的竞争者在起点上高出很多。
税收筹划的一般领域针对各种小型企业，有几种税务筹划是适合的。
筹划包括会计和库存估价的方法，计时设备的采购，家庭成员之间的收入，税收优惠的福利计划和投资的选择。
还有的税务筹划，是针对某些地区某些商业形式，即独资企业，合伙企业，C类公司和S公司等。
一般税务筹划描述如下：会计方法。
会计法：指经营者在基本规则和指导下做出相应的财务记录和编制财务报告。
主要有两种方法已备案：现金制和应计制。
小企业主必须根据该企业的法定形式和销量决定使用哪种方法，或者是根据国际税收服务提出税收要求。
会计方法的选择是一种税收筹划问题，因为它会影响到小型企业在计算年的拖欠税款。
根据实时的现金流，会计记录现金收入和支出。
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外文文献翻译企业税收筹划的主要途径纳税筹划是在严格执行税法前提下，尽量减少缴税，习惯称其为节税。
企业要正确地进行节税，需要通过以下的主要途径。
一、选择合理的筹资方式。
根据我国现行税法规定，企业的借款利息支出在一定范围内可以税前列支，而股息支出则只能在企业的税后利润中列支。
从节税的角度看，企业适度向银行借款和企业间的相互融资，要比企业直接向社会筹资优惠。
二、选择合理的交易对象。
我国现行增值税制度规定有一般纳税人和小规模纳税人之分，选择不同的供货对象，企业所负担的税负则不相同。
例如，当供货方系增值税一般纳税人时，企业购进货物后，可按销项税额抵扣相应的进项税额后的余额缴纳增值税；如果购买小规模纳税人的货物，不能取得增值税专用发票的，其含有进项税额不能抵扣，税负比前者要多。
如开专用发票也可抵扣一部分。
三、“避重就轻”转换纳税义务。
企业将高纳税义务转换为低纳税义务，是指在同一经济行为中，有多种税收方案可供选择时，纳税人避开“高税点”，选择“低税点”，可减轻纳税义务。
最典型的例子就是对兼营非应税劳务进行的节税筹划。
从税收角度来看，兼营主要包括两种：一是税种相同，税率不同。
例如供销系统企业，一般既经营增值税率为17%的生活资料，又经营增值税率为13%的农用生产资料等。
二是不同税种，不同税率。
该种类型通常是指企业在其经营活动中，既经营增值税项目，又涉及营业税项目。
四、合理列支各项费用。
企业可以在不违反税法和财务制度的前提下，通过对各项费用充分合理的列支，对各项可能发生的损失进行充分估计，缩小税基，减少应纳税所得额。
对于国家允许在费用中列支的项目，如分别按计税工资总额的2%、14%、1.5%提取的职工工会经费、职工福利费、职工教育经费，应尽可能地提足提全。
对于一些可能发生的损失，如坏账损失等，企业应充分预计，在税法允许的范围内尽可能按上限提足准备金。
这既符合国家税法和财务制度的规定，又能收到节税的效果。
五、降低应纳税额。
影响应纳税额的因素有两个，即计税基数和税率，计税基数越小，税率越低，应纳税额也越小。
进行税务筹划可从这两个因素入手，找到合法的办法来降低应纳税额。
例如，某企业2005年12月30日测算的应纳税所得额为10.02万元，则企业应纳所得税25050元（100200×25%）。
如果该企业进行了税务筹划，支付税务咨询费200元，则该企业应纳税所得额100000元（100200-200），应纳所得税27000元（100000×27%），通过比较可以发现，进行税务筹划支付费用仅为200元，却节税6066元（33066-27000）。
六、权衡整体税负的轻重。
例如，很多筹划方案中都有增值税一般纳税人与小规模纳税人选择的筹划。
如某企业是一个年不含税销售额90万元左右的生产企业，企业每年购进的材料不含增值税的价格大致在70万元左右。
该公司会计核算体系健全，有条件认定为一般纳税人。
如果是一般纳税人，公司产品的增值税适用税率是17%，应纳增值税 3.4万元（90×17%-70×17%）；如果是小规模纳税人，税率为6%，应纳增值税5.4万元（90×6%）＞3.4万元。
因此，仅从增值税角度考虑应选择一般纳税人。
但实际上，虽然小规模纳税人多纳增值税2万元，但其进项税额11.9万元（70×17%），虽然不能抵扣却可以计入成本，从而增加成本11.9万元，所得税减少2.975万元（11.9×25%），大于多纳的增值税2万元。
因此，企业在选择税务筹划方案时，不能仅把目光盯在某一时期纳税较少的方案上，而要考虑企业的发展目标，选择有利于增加企业整体收益的方案。
七、充分利用税收优惠政策。
对于纳税人来讲，利用税收优惠政策进行纳税筹划的重点在于如何合理运用税收政策法规的规定，适用较低或较优惠的税率，妥善规划生产经营活动，使其实际税负最低，以达到节税的效果。
例如，根据我国税法规定，对国务院批准的高新技术产业开发区内的高新技术企业，自投产年度起免征所得税2年。
对企业利用废水、废气、废渣等废弃物为主要原料进行生产的，可在5年内减征或免征所得税。
此外，对用于支持农业以及教科卫事业发展的投资，国家也有不同的税收优惠政策。
企业经营者应参照政策规定，综合比较投资环境、投资收益、投资风险等因素，决定投资区域、投资方向以及投资项目，合理进行税务筹划，以减少企业税负。
需要说明的是，纳税人运用上述方法进行节税，一方面，要符合企业生产经营特点，统筹规划，综合考虑，不能顾此失彼；另一方面，要经常学习，了解国家税制改革动向及优惠政策措施的修订和调整，准确把握税收法规政策界限，深入研究税法的相关规定，防止因节税而引发其他问题。
外文文献原文Enterprises of the major means of tax planning Tax planning is the premise of strict enforcement of tax laws to minimize tax, customs tax called. Enterprises to carry out the correct tax, the need for the adoption of the following major route of transmission.First, reasonable means of financing options. In accordance with the provisions of China's current tax law, corporate interest payments on the loan within a certain range can be pre-tax expenses, and dividends can only be spending the after-tax profits of enterprise expenses. From a tax point of view, appropriate to the bank business loans and financing between enterprises, rather than directly to thefund-raising benefits.Second, a reasonable choice of trading partners. China's existing value-added tax system has a general taxpayers and small-scale taxpayers on the points, choose a different supplier object, the tax burden on enterprises is not the same. For example, when the Department of suppliers of value-added tax general taxpayer, the business after the purchase of goods, according to the amount of tax deduction of input tax amount of the corresponding balance after payment of value-added tax; if the purchase of goods for small-scale taxpayers, VAT can not be achieved Its not contain the amount of input tax deduction, the tax burden more than the former. Such as open invoices can also be part of deduction.Third, "the easy way out" tax conversion. Enterprises will be converted tohigh-tax low-tax, refers to economic activities in the same, there are a variety of revenue options to choose from, the taxpayers to avoid "high-tax point", choose the "low tax" and reduce the tax liability . The most typical example of this is to runnon-taxable to the tax planning services. From the tax point of view, run mainly two: First, the same taxes, different tax rates. Systems such as supply and marketing enterprises, the general operating tax rate is 17% of the means of subsistence, but also the operating value-added tax rate of 13% of the agricultural means of production and so on. Second, different taxes, different tax rates. This usually refers to types ofenterprises in their business activities, both value-added business project, the project also involves the business tax.Fourth, the cost of reasonable expenses. Enterprises does not violate tax laws and financial system under the premise of the full cost of the reasonable expenses, that may occur on the full estimated losses and narrow the tax base and reduce the amount of taxable income. Countries allow for costs incurred in the projects, such as wages, respectively, the total amount of tax by 2%, 14%, 1.5% extracts of trade union funds, staff welfare, staff education funding should be sufficient to mention as much as possible to the whole. For some of the losses that may occur, such as bad debt losses, businesses should be fully expected in the tax law as far as possible the extent permitted by the cap enough to reserve. This is in line with the national tax law and financial system, can receive the tax effect.Fifth, to reduce tax liability. Factors that affect the tax liability there are two, namely, tax base and tax rates, the smaller the tax base, lower tax rates, tax liability is also smaller. Tax planning can start from these two factors to find legitimate ways to reduce tax liability. For example, an enterprise December 30, 2005 estimated taxable income amounted to 100,200 yuan, the enterprise income tax liability 25050 yuan (100200 ×25%). If the corporate tax planning, tax consulting fees to pay 200 yuan, the corporate taxable income 100,000 (100200-200), income tax liability 27,000 yuan (100000 × 27%), can be found by comparing, for tax planning to pay only 200 yuan, 6066 yuan tax is (33066-27000).Sixth, to weigh the severity of the overall tax burden. For example, manyvalue-added tax planning programs have the general taxpayer and the taxpayer to choose small-scale planning. If an enterprise is a non-tax-year sales of about 900,000 yuan of production enterprises and enterprises to buy the materials each year the price of non-value-added tax of 70 million or less. The company's accounting system, the conditions identified as the general taxpayers. If that is the general taxpayer, the company's products are value-added tax rate applies to 17% capital gains tax liability 34,000 yuan (90 × 17% -70 × 17%); If it is small-scale taxpayers, the rate is 6%, 5.4 VAT liability million (90 × 6%)> 3.4 million. Therefore, from the perspective ofvalue-added tax general taxpayer should be selected. But, in fact, althoughsmall-scale VAT taxpayers pay 20,000 yuan, but the input tax amount of 119,000 yuan (70 × 17%), although it can not offset the costs, thereby increasing the cost of 119,000 yuan, the income tax reduction of 2.975 million (11.9 × 25%), than pay a 20,000 yuan of value-added tax. Therefore, the business tax planning in the selection of programs, not only to look in a certain period of time watching the program on tax less, and to consider business development goals, to choose to increase their overall revenue program.Seventh, take full advantage of preferential taxation policies. For taxpayers, the use of tax incentives for tax planning focuses on how the rational use of tax policies and regulations shall apply to the lower or more favorable tax rates, a well-planned production and operation activities, the actual tax burden to a minimum in order to achieve Festival tax effect. For example, according to China's Law of the State Council for approval of high-tech industrial development zone of the high-tech enterprises, since the production from the fiscal year income tax exemption for 2 years. To-business use of wastewater, waste gas, waste residue and other waste as the main raw materials for production, 5 years in the income tax reduction or exemption. In addition, to support agriculture and the development of UNESCO Wei investment, countries have different tax incentives. Business operators should refer to policy, comparing the investment environment, investment income, investment risks and other factors, decided to invest in the region, investment direction, as well as investment projects, a reasonable tax planning, in order to reduce the corporate tax burden.It should be noted that the above-mentioned methods taxpayers use tax, on the one hand, it is necessary to comply with the characteristics of enterprise production and management, overall planning, comprehensive consideration and can not cater for all kinds; On the other hand, to keep learning and understanding of national trends and policies on tax reform measures amendments and adjustments, accurately grasp the limits of tax regulations and policies, in-depth study of the relevant provisions of tax laws to prevent tax and give rise to other problems.。