Research On Tax Planning Of Enterprise Groups

The tax planning of the enterprise group is a strategic planning activity to reduce the group's overall tax burden and increase the group's after tax profits from the overall development of the group.

The tax planning of enterprise groups has the characteristics of being advanced, purposeful and overall. It is an important part of the financial strategy of modern enterprise groups.

As for the enterprise group, because its capital stock is thick, the effect of revitalize and dispatch is obvious. Therefore, it is superior to independent enterprises in strategic choice, annexation and reorganization, operation adjustment and so on.

The basic idea of tax planning for enterprise groups is that tax planning for enterprise groups can be generally considered from six aspects: 1., narrowing the tax base of group enterprises or groups.

Reducing the tax base can reduce the amount of tax payable, such as maximizing the cost deduction and amortization within the allowable limits and limits of the tax law, and reducing the taxable income.

The 2. low tax rates apply to the group.

In the tax law, there are various tax rates except for a few tax categories. Some also adopt progressive tax rates, which have broad space for tax planning.

The 3. annual income of a group enterprise or group.

The treatment of income attribution can be achieved through the increase or decrease or apportionment of items such as income, cost, loss, cost, etc., but it is necessary to correctly predict the formation of sales, the payment of various fees, understand the trend of group profit and make reasonable arrangements to get the maximum benefit.

The 4. group postpone the tax term as a whole.

Capital has time value, delaying the tax payment period, and can learn from the interest of similar interest free loans.

Generally speaking, the longer the tax payable is, the more profits will be gained.

When the economy is in the period of inflation, the financial benefits of delaying taxes are more obvious.

5., the tax burden should be reduced to reduce the group's tax burden.

The shift of tax burden exists in economic pactions, and is realized through price changes. The complex investment relationship within the group and the frequent trade dealings create conditions for the pfer of taxes to the group.

The tax burden of the 6. tax groups on the balance group.

Through the group's overall regulation, strategic development and investment extension, the main business is segmented and pferred so as to achieve the balance and coordination of tax burden among various tax paying enterprises within the group, thereby reducing the overall tax burden of the group.

Two, tax burden shifting planning strategy. Tax burden shifting refers to the process of pferring tax burden to others after paying taxes, which aims to eliminate or reduce tax liability.

Basically, the pfer of tax burden is not related to the tax law. It only pfers the tax burden to others by controlling the price in the process of commodity purchase and sale, and its behavior does not infringe upon the interests of the state, nor does it constitute an illegal act.

Therefore, tax burden pfer is generally favored by enterprise groups.

The elasticity of supply and demand of commodities or production factors determines whether tax can be pferred to crops, how to pfer crops and how effective it is to pfer.

On the issue of tax pfer, it is more common that some taxes are pferred back to buyers of goods or factors of production by raising the prices of commodities or production factors, while the other taxes are forwards to the providers of commodities or production factors by lowering the price of commodities or factors of production.

As for the extent of crop rotation, it depends on the comparison of supply and demand elasticity, that is, the ratio between supply elasticity and demand elasticity.

The enterprise group is composed of numerous independent enterprises. Some enterprises can act as intermediaries in the whole economic chain.

Middlemen should be able to flexibly adjust their demand elasticity according to the change of consumer demand.

If demand elasticity is greater than supply elasticity, the possibility of moving forward to crops is greater, that is, taxes will fall more on commodity or factor of production providers; if demand elasticity is less than supply elasticity, the larger part of the backward crop will be that taxes will fall more on buyers or end consumers.

Besides the elasticity of supply and demand, the important factors that affect tax burden pfer include tax scope, tax calculation method, economic paction and market structure type.

It is generally believed that the wider the scope of taxation is, the easier it is to shift the tax burden.

From the amount of tax, because the tax is not affected by price changes, the tax burden is difficult to pfer. The ad valorem tax, because the amount of tax fluctuates with the fluctuation of the price, it is easier to pass the tax burden.

The pfer of tax burden is usually achieved by pferring taxes to the price of goods or factors of production. It is realized in the course of economic pactions, and economic pactions are the necessary conditions for the pfer of tax burden.

For different market structures, tax burden shifting is different.

It is generally believed that under the condition of perfect competition, taxes can not be pferred in the short term.

But in the long run, under the condition of constant production cost, each producer is a force that can not be underestimated in raising the price of the whole industry. The tax revenue will eventually be pferred to consumers in the price.

Under the monopolistic competition market, a single producer can adjust the price appropriately by using the difference of his products, so that some taxes can be pferred back to consumers.

Three, set up core holding company and financial center planning strategy. Group Holding Companies is an organizational structure formed by the group's participation and control of equity participation.

Because there are differences between the tax collection scope and tax categories among different enterprises within the group, the tax rates vary, and there may still be enterprises that are exemption from tax concessions.

In this way, the core holding company can balance the group tax burden and reduce the tax burden level of the group through financial decision and strategic adjustment.

The main methods of operation are: first, the core holding company is located in the special economic zone or high and new technology development zone, which can have greater initiative to enjoy tax preferences and carry out tax planning activities.

The two is the merger and acquisition of loss making enterprises.

Through low cost expansion, we can achieve industrial restructuring, and we can also enjoy the tax benefits of profit and loss compensation.

The three is to separate or form enterprises.

When separating or forming a new enterprise, the group has the decision-making power to choose its organizational form. In order to reduce the risk of splitting up or forming a company, it is necessary to calculate the tax burden on the establishment of a branch or a subsidiary.

The four is to make use of the resources and reputation advantages of the group to raise funds as a whole, and then divide the loans at different levels to solve the problem of financing difficulties within the group and adjust the group's capital structure and debt ratio.

In carrying out the above plan, the financial operation of the group must be centralized. The tax planning and operation of the core holding company should be combined with the establishment of the financial center and capital operation.

For the group as a whole, the financial center undoubtedly plays the role of the bank and borrows loans from the operating units within the group. Its function is to concentrate on the financial risks of the company.

These financial centers can not only save money due to centralized financial functions, but also benefit the group's financial centers in the areas with more developed tax treaty networks. They can enjoy the advantages of withdrawing or withholding tax and business tax from loans. At the same time, a large amount of interest income can be planned and allocated through the financial center, so that the effect of tax credit or delaying tax can be obtained.

Four, reciprocal pricing planning strategy, mutual pricing, also known as pfer pricing, is the group's internal price determined by the group's strategic objectives, selling goods, providing services and specialized technology, and lending activities between related enterprises.

It is not determined by market supply and demand, but is mainly subordinated to the overall profit of the group.

The so-called affiliated enterprises are enterprises with independent legal personality but some related interests.

The affiliated enterprises may be the relationship between the parent subsidiary company and the joint venture company.

Reciprocal pricing itself may contain multiple purposes, and the reciprocal pricing for reducing tax burden is a means to reduce the overall tax burden of enterprises through profit pfer among related enterprises.

The way of reciprocal pricing between affiliated enterprises is mainly as follows: first, the cost and profit of products are affected by the selling price of spare parts and finished products; the two is to charge higher or lower pport costs, insurance premiums and commissions to pfer profits among related enterprises; the three is to influence the cost and profit level of products through the purchase price and the period of use of fixed assets between related enterprises; and the four is to influence the cost and profit of related companies by providing consultation, royalties, interest costs and rents of loans.

For example, the income tax rate at the headquarters of Galaxy Group is 33%. One of its subsidiaries, the Yangtze River company, employs disabled people to meet the required number of policies, and is recognized as a welfare enterprise and temporarily exempted from corporate income tax.

The headquarters of Yinhe Group costs 80 thousand yuan, a group of goods that can be priced at 120 thousand yuan, and sells it to the Yangtze River company at a price of 100 thousand yuan. The Yangtze River company finally sold it to the group at a price of 140 thousand yuan.

How does this pricing affect the overall tax burden of the group?

According to the price of 120 thousand yuan, the galaxy group should pay a tax of (12-8) x 33% = 13 thousand and 200 yuan, and the actual tax burden of the Galaxy Group is only (10-8) x 33% = 6 thousand and 600 yuan at the reciprocal price.

After adopting reciprocal price, galaxy group can achieve 6 thousand and 600 yuan tax savings.

As a very effective tax planning method among group enterprises, the mutual benefit pricing method generally has the following two plans: there are differences in the tax rates among the 1. enterprises within the 1. groups. For example, there are A and B enterprises, the tax rate applicable to A enterprises is high, the tax rate applicable to B enterprises is low or the tax rate is in tax-free period. When A enterprises sell products to B enterprises, they should sell at a low price; on the contrary, when B enterprises sell products to A enterprises, they should raise their prices.

There are differences in profits and losses among tax enterprises in the 2. groups. For example, there are C and D enterprises, C enterprises are in a high profit period, D enterprises are in a loss period, and profits can be pferred through reciprocal pricing.

But reciprocal pricing must be used to pfer profits.

Although the market price of commodities is always changing in the market economy, the pricing of commodities gradually becomes their own market decision, which provides conditions for the tax planning through reciprocal pricing.

However, when the enterprise group adopts the reciprocal pricing method to make tax planning, the determination of reciprocal pricing can not violate the trading rules and value laws of the market economy.

The existing tax law clearly stipulates that pactions between affiliated enterprises should be conducted according to pactions between independent enterprises, otherwise the tax authorities will make adjustments.

Reciprocal pricing is a skill that needs to be carried out within a reasonable range of commodity price fluctuations and for good reason.

Five, leasing tax reduction planning strategy leasing is also an important planning method for enterprise groups to lighten the tax burden.

Leasehold can gain double benefits for leaseholders; one can avoid the burden and risk due to long-term machinery and equipment; two is to reduce the profits of the enterprise by paying rent in the operation, thus reducing the tax burden.

At the same time, because the rent payment is relatively stable, compared with the purchase of machinery and equipment, it has greater balance.

When purchasing equipment, the price is usually one-time payment, even if the installment payment is adopted, the payment time of the funds is still relatively concentrated.

The way to rent the rent can be mutually agreed upon when the contract is signed, so that the leased enterprise can reduce the profit level of the enterprise through the balance of rent payment from the angle of lightening the tax burden, so that the profits can be shared equally in all the years so as to lighten the tax burden.

When a lessor and a lessee belong to the same interest group, leasing can enable them to pfer assets from one enterprise to another directly and openly.

One party in the same interest group, for certain tax purposes, sublets the profitable production items together with the equipment in the form of leasing to the other party, and receives the relatively full rent according to the relevant regulations, which ultimately reduces the tax burden of the interest group.

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