税收筹划论文英文参考文献

所谓避税是指企业为了实现利润最大化和税负最低化，研究各国税收法律之间的差异，策划个人或集团内部财务节税计划，以规避纳税。 外资企业都各有避税秘方，虽然说避税违反了税收立法意图，有悖于政府的税收政策导向，但避税并不违法，法律上存在合理避税之说。正因如此，很多外资企业采取各种招术，以达合理避税的目的。 转让定价毕马威会计师事务所张小姐透露，他们在审计外资企业的时候，常会遇到一些利用现有中国税法不健全进行转让定价的避税方法。 张小姐举例说，她在审计中，就遇到一家总部设在国外分部设在国内的加工制造企业，总部有意提高原材料成本价格，增大负债，在售价不变的情况下，使收益减低，甚至出现亏损，在亏损后，还会增加投资，常年如此，税务部门拿这种做法也无可奈何。这种做法被审计人员叫做“转移定价”。这家企业“长亏不倒”的做法在很多外企中也很盛行。 为什么要集中财务管理？谈财务报告分析的四个视角 转让定价是现代企业特别是跨国公司进行国际避税所借用的重要手段。在现代经济生活中，许多避税活动，不论是国内避税还是国际避税，都与转让定价有关。它们往往通过从高税国向低税国或避税地以较低的内部转让定价销售商品和分配费用，或者从低税国或避税地向高税国以较高的内部转让定价销售商品和分配费用，使国际关联企业的整体税收负担减轻。 贷款高利率利用专有技术等无形资产作价高于国际市场价格，或隐藏在设备价款中的一种手法。外商利用人们不了解设备和技术的真实价格，从中抬高设备价格和技术转让价格，将企业利润向境外转移。它们在抬高设备价款的同时，把技术转让价款隐藏在设备价款中，以躲避特许权使用费收入应纳的预提税。 劳务收费标准“高进低出”。关联企业之间相互提供服务或劳务，通常是境外公司收费高，境内公司收费低甚至不收费。有的还虚列境外公司费用。 资产评估提高折旧张小姐曾遇到过一家香港公司，每年都要对其房地产进行价值评估，其在华子公司因为要与香港母公司进行合并报表，所以也要同时评估其在华房产。这也是外资一种避税的有效方法。如房地产评估增值，每年计提的折旧也会相应的增加，纳税自然也会相应减少。 国际避税地建公司记者还从一位曾在台湾某企业工作过的陈小姐那里得知，在避税港注册也是一种办法。他们那里曾经也采用过相同的办法。在国际避税地建立公司，然后通过避税地的公司与其他地方的公司进行商业、财务运作，把利润转移到避税地，靠避税地的免税收或低税收减少税负。在长三角地区，一些外资企业的投资方来自英属维尔京群岛等地方，而实际在岛上，它们可能只有一间办公室。 运用避税港进行避税是跨国纳税人减轻税负增加收入的手段之一，而维持税收制度在筹措国家财政资金方面的有效性，又是各国税务当局面临的重要任务之一。在跨国纳税人不断运用避税港的情况下，国家的税收权益不断遭到损害，税收收入受到影响，税收的公平原则也相应遭到破坏。因此，许多国家尤其是发达国家特别注意如何防止跨国投资经营者运用避税港从事避税活动。 其他方法层出不穷外企避税另一主要手段是利用关联交易，高进低出。这种手段占到避税金额的60%以上。另外，目前外商投资中国的资金中，60%以上是借贷资金，即便是一些实力雄厚的国际公司也向境内外银行借大量资金，利用税前列支利息，达到少交或免交企业所得税的目的。 反避税涉及到社会经济生活的各个部门。税收制度不够完备，地区间、部门间的不协调，是避税形成的客观原因。专家指出，应从税法和征管两方面完善和加强现有税收体制。首先，现行的涉外的税法规定外商投资企业享受着和内资企业不同的税收政策，这种税收设置，为合法避税行为提供了一个很大空间。只有内外资企业所得税合并，才能够进一步完善税法和严格征管，在反避税上从根本上打下一个非常好的基础，否则，现在两套税制，随意性很大。 其次是征管方面。在征管手段上要跟上计算机的信息控制，另外也涉及到出口退税和税问题，要求海关、外贸部门和税务机关三方面能够迅速信息相通，这些方面和国际上都还存在差距，需要进一步改进。

提供一些合理避税分析的论文参考文献，供参考。[1] 李玉梅. 企业合理避税与偷逃税的区别[J]. 财会研究, 2008,(03) . [2] 张国臣. 企业合理避税的筹划[J]. 长江大学学报(社会科学版), 2007,(S1) . [3] 治喜平. 浅析企业合理避税[J]. 科技咨询导报, 2007,(16) . [4] 王晓燕. 浅谈企业如何合理避税[J]. 辽宁经济职业技术学院(辽宁经济管理干部学院学报), 2007,(03) . [5] 王晓燕. 浅谈企业如何合理避税[J]. 科技咨询导报, 2007,(19) . [6] 李争艳. 合理避税方法之我见[J]. 内蒙古科技与经济, 2007,(11) . [7] 杨武俊. 税收筹划与增值税合理避税[J]. 太原科技, 2007,(09) . [8] 吴晓微. 工薪层个人所得税的合理避税筹划方案[J]. 中国乡镇企业会计, 2008,(03) . [9] 邓娜,吴君民. 试论企业税务筹划与合法性避税的界限[J]. 价值工程, 2008,(01) .

I issue you oh, my just participated in tax revenue preparation training! Tax revenue preparation First lecture of tax revenue outline First, our country present tax law system content. The our country present tax system speaking of its substantive law, after is the founding of the nation passes through several times of bigger reforms by □i the evolution but Lei, approximately divides into six kinds according to its nature and the function: (1) pasts the tax class. Including increment duty, excise tax, business tax. Mainly in the production, the circulation or service industry displays the control action. (2) resources tax class. Including resources tax, cities land use tax. Mainly is to because of the development and the grading income display control action which forms using the natural resource difference. (3) income tax class. Including enterprise income tax, foreign investment enterprise and foreign enterprise income tax, personal income tax. Mainly is forms after the national income, to produces operator's profit individual net income display control action. (4) specific goal tax class. The city maintenance 建设税, the land increment duty, the vehicles purchase tax, the cultivated land take the tax. Mainly is for achieve the specific goal, to specific object and specific behavior display control action. (5) property and behavior tax class. Including property tax, city real estate tax, the vehicle ship use tax, the vehicle ship uses the fee of permit, the stamp duty, 屠宰税, 契税. Mainly is to certain properties and the behavior display control action. (6) customs duty. Mainly is to the turnover our country border cargo, the goods levies. The above 税种 center customs duty responsibly levies the management by the customs, other 税种 responsibly levy the management by the tax affairs institution. Second, tax affairs organization establishment and tax revenue collection scope division. (1) tax bureau. Including the province, the autonomous region, the municipality country tax bureau, the area, the level city, the autonomous prefecture, the pledge country tax bureau, the county, the county level city, the flag country tax bureau, levies the sub-bureau, the tax affairs institute. (2) place tax bureau. Including the province, the autonomous region, the municipality place tax bureau, the area, the level city, the autonomous prefecture, the pledge place tax bureau, the county, the county level city, the flag place tax bureau, levies the sub-bureau, the tax affairs institute. Third, the tax revenue levies the management scope division (1) national tax bureau system collection project: The increment duty, the excise tax, the vehicles purchase tax, the railroad department, various banks general headquarters, each insurance main corporation concentrate the business tax, the income tax, the city maintenance which pays 建设税, the central enterprise pays the income tax, the central committee and the place respective enterprise, the institution compose the joint management enterprise, the stock-company type enterprise pay the income tax, the place bank, the non- bank finance enterprise pays the income tax, the sea petroleum enterprise pays the income tax, the resources tax, the foreign investment enterprise and the foreign enterprise income tax, proves the volume transaction tax, in the personal income tax the part which obtained levies to the savings deposit interest, the central tax fine for delayed payment, pays a past-due tax, the fine. (2) place tax bureau system collection project: The business tax, the city maintenance 建设税 (including above by national tax bureau is not the income tax, the personal income tax which collection part) the original place state-owned enterprise, the collective enterprise, and the private enterprise pays (not including above part which obtained levies by national tax bureau system collection savings deposit interest), the resources tax, the cities land use tax, the farming takes the tax, the land increment duty, the property tax, the city real estate tax, the vehicle ship use tax (on January 1, 2007 gets up by original vehicle ship use tax and vehicle ship use fee of permit merge revision), the stamp duty, 契税, 屠宰税, the banquet tax and its the place attach, the local tax fine for delayed payment, pays a past-due tax, the fine. Based on 国税 sends [ 2002 ] the 8th article notice stipulation; On January 1, 2002 gets up, handles the company in all levels of industry and commerce administration department which the establishment (starts doing business) registers, its enterprise income tax responsibly levies the management by the national tax bureau. (3) central authorities and the local authority tax revenue income divides 1st, central authorities fixed income: The excise tax, the vehicles purchase tax, the customs duty, the customs generation drafts import link increment duty and so on 2nd, local authority fixed income: The cities land use tax, the cultivated land take tax, land increment duty, property tax, city real estate tax, the vehicle ship use tax, 契税 and so on. 3rd, the central authorities and the local authority share the income: (1) the increment duty (not import link increment duty which drafts including customs generation): The central authorities share 75% local authority to share 25% (2) business tax: The Ministry of Railways, various banks general headquarters, each insurance company main corporation concentrates the part which pays to turn over to the central authorities, other turn over to the local authority. (3) enterprise income tax, foreign investment enterprise and foreign enterprise income tax: The Ministry of Railways, various banks general headquarters and the sea petroleum enterprise pays the part turns over to the central authorities, other parts of central authorities share 60%, the local authority share 40% (4) personal income tax: Besides the savings deposit interest personal income tax, other parts of central authorities share 60 % The local authority shares 40% (5) resources tax: The sea petroleum enterprise pays the part turns over to the central authorities, other parts turn over to the local authority. (6) city maintenance 建设税: The Ministry of Railways, various banks general headquarters, each insurance company concentrate the part which pays to turn over to the central authorities, other turn over to the local authority. (7) stamp duty: The card □□ transaction stamp duty income 94% turns over to the central authorities, other 6% and other stamp duty income turn over to the local authority. Second lecture of increment duty The increment duty is sells the cargo to our country within the boundaries of or provides the processing, the repair makes repairs the service, as well as the import cargo unit and individual, it obtains the cargo or the dutiable service sales volume, as well as the import cargo amount computation tax money, and the implementation tax money arrives buckles the system one kind to past the tax. First, taxation scope (1) sales or import cargo (2) provides the processing, the repair makes repairs the service (3) regards with the sales cargo behavior 1st, pays the cargo the other people to sell goods for the state 2nd, the sale sells goods for the state the cargo 3rd, is equipped with two above organizations and the implementation unifications calculation taxpayer, transfers the cargo from an organization to other organizations uses in to sell, but the correlation organization is located in identical county (city) being an exception 4th, from will produce or the request processing cargo uses in the non- dutiable project 5th, from will produce, the request processing or the purchase cargo behavior investment, will provide for other units or the individual operator 6th, from will produce, the request processing either the purchase cargo assigns for the shareholder or the investor 7th, from will produce, the request processing cargo uses in the collective welfare or the individual consumption 8th, from will produce, the request processing or the purchase cargo free bestows the other people (4) mix sale behavior A sales behavior if both involves the increment duty dutiable cargo and to involve the non- dutiable service, for the mix sale behavior, specifically said, the non- dutiable service is for directly sells, the two which one batch of cargos provides is the close connected subordinate relations. If for sells transportation service which this enterprise product provides; Receivable bill opposite party pastes the interest and so on. (5) concurrently camp non- dutiable service behavior Increment duty taxpayer concurrently camp non- dutiable service, if not separately calculates its sales volume and the turnover, one and levies the increment duty. Second, taxpayer (1) small scale taxpayer 1st, production configuration enterprise, year sales volume below 1000000 2nd, retail sales, wholesale commercial department, year sales volume below 1800000 (2) common taxpayer 1st, the year sales volume surpasses the stipulation standard 2nd, the production configuration enterprise conforms to the common taxpayer to recognize the condition, the newspaper authorizes by the tax affairs department, to recognize for the temporary common taxpayer, the year examines qualified transfers the common taxpayer. 3rd, business trade enterprise reports by the tax affairs department authorizes to recognize the common taxpayer, the tax payment counselling time is ordinary many to 6 months, each time sells the special-purpose receipt quantity in the counselling time not to have to surpass 25; High writes a check the quota not to surpass 10,000 Yuan; The same month authentication income tax amount, next time will be able to arrive at the buckle; The enterprise buys the quantity according to each time the collar not to be able □ the crane surprised rheumatism to unite □ the camp need, may apply once more, but must press down the special-purpose receipt sales volume which collar buys and draws up 4% to deliver in advance the increment duty, delivers in advance the increment duty may arrive in this time due payment tax amount reduces. Third, tax rate (1) basic tax rate 17% (2) low tax rate 13% (3) levying rate commercial department small scale tax payment artificial 4%; Other enterprise small scale tax payments artificial 6% Fourth, the computation sells the tax amount sales volume confirmation Under (1) general sales way sales volume confirmed that, To buys outside the complete cost and the price which the buyer gathers the expense (handling charge, subsidy, fund, collection fee, returns profit, penalty, deferred payment interest, 包装费, packing material deposit, and so on outside each kind of nature price collects fees) Under (2) different sales way sales volume confirmation 1st, the discount sale (because buys supplier to purchase merchandise quantity to be bigger and so on reason for buys supplier price preferential benefit): If sells 折扣额 separately indicates on the identical receipt, may after the discount remaining sum computation increment duty, if writes the receipt in addition, how no matter the finance does process, does not have to deduct. 2nd, the sales discount (is for encourage to buy supplier early to pay money promises for buys supplier one kind of preferential benefit): Does not have the abatement 计税 from the sales volume. 3rd, sells the booklet to let (after is because sells occurs because cargo variety quality causes sales volume reduction), may fold lets after the loans for the sales volume computation increment duty. 4th, adopts to old exchanges the way sale (taxpayer when sells the oneself cargo, paid recycling second hand goods behavior) Should according to the new goods same time selling price definite sales volume. Does not have to deduct the second hand goods purchase price (money jewelry to old to exchange service to be an exception) After 5th, takes repays principal the sales way sale (sales cargo, either returns at different times to certain deadline by seller for buys supplier completely or partial costs) Its sales volume is the cargo selling price, does not have to deduct from the sales volume repays principal the disbursement 6th, adopts by the thing easy way sale (to refer to buying and selling both sides mutually to settle accounts by same level cost cargo) Both sides both should make buying and selling processing, to the cargo calculation sales volume computation which respectively sends out sells a tax 7th, packing material deposit: Alone records account calculation the packing material deposit, the time within a year, also not expired, does not merge the sales volume 计税, outside, but to exceeds the time limit has not drawn back or year above deposit fixes a price the income and counts the sales volume 计税. 8th, old machine, old vehicle sale: The selling price has not surpassed the original value, exemption increment duty Fourth, income tax amount computation (1) permits arrives at the buckle the income tax amount The increment tax amount from the seller which 1st, which obtains on the increment duty special-purpose receipt indicates 2nd, obtains the increment tax amount from the customs which pays duty in the certificate to indicate 3rd, the agricultural product which buys into to the agricultural producer or the small scale taxpayer, according to purchases the cost which in the certificate indicates, according to 13% deduction rate computation income tax amount, from when the time sells in the item to deduct 4th, buys from outside the transport expense which the cargo (fixed asset is an exception) pays according to the transport expense (including construction fund) The amount 7% deduction rate computation income tax amount arrives at the buckle 5th, gets up from December 1, 2004, the increment duty common taxpayer purchases the tax to control the increment tax amount which the cash register pays, permits in when the time arrives at the buckle (2) does not have to arrive at the income tax amount which buckles 1st, purchases the fixed asset 2nd, uses in a non- dutiable goal to purchase the cargo or the dutiable service 3rd, uses in the tax-free goal to purchase the cargo or the dutiable service 4th, uses in the collective welfare or the individual consumption purchases the cargo or the dutiable service 5th, the unusual loss purchases the cargo 6th, the unusual loss purchases the cargo or the dutiable service which in the product, the finished product consumes 7th, has not obtained and the preserved increment duty 扣税 certificate according to the stipulation, or has not arrived at the income tax amount according to the stipulation application which buckles Fifth, the use increment duty receipt should pay attention question (1) in obtains in front of the common taxpayer qualifications from to buy the increment duty special-purpose receipt which the supplier obtains not to give arrives at the buckle (2) obtains the increment duty special-purpose receipt, the customs pay duty tax law and so on certificate stipulated may arrive at the certificate which buckles in, must in draw up the date 90 to open authenticates to the tax affairs institution, otherwise does not give arrives at the buckle (3) sixth branch after authentication income tax amount, if this cargo change use, < uses in the above (2) project > to be supposed to make the income tax amount in the same month to exit like uses in to construct the project, the staff benefit, the overseas Lei material processes the duplicate exportation, the feeding processing domestic carry-over, the goods in stock 盘亏 damages and so on (4) the increment duty special-purpose receipt which obtains according to the stipulation (money for a ticket symbol, only has not obtained records account association or arrives buckles association) (5) (has not established receipt control system, non- specialist according to the stipulation storage increment duty special-purpose receipt takes care of, does not have specially deposits place, has not bound book according to request, arbitrarily destroys basic association order, loss receipt, damages special-purpose receipt and so on) (6) does not have to draw up at will red flushes the increment duty special-purpose receipt (7) exports the cargo to be supposed to draw back the tax amount (production enterprise to export cargo to exempt, to arrive at, draws back Shanghai report form 19 items), will be supposed to the tax reimbursement declaration next time increment duty Shanghai report form 15 prompt declaration