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managed to break through the &quot

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  • Started 12 years ago by prvr9nDp2d

  1. prvr9nDp2d
    Member

    <p> managed to break through the "pipeline company" tax avoidance tax inspection case
    <br. />
    "pipeline company", is a typical method of tax evasion, is usually a company, but it may also be a partnership, trust or similar entities, as long as it has the right to enjoy the benefits of agreement on the line. This tax will generally lead to the income source of damage, because the tax treaty benefits are extended to originally should not receive these benefits people.

    recently, Tanggu IRS in the transfer of quicken 2013 ownership transaction with the overseas examination, through the investigation and careful analysis, clever and quick mining forensics, successfully broke the "pipeline company" tax avoidance fence, defend our country tax revenue jurisdiction. A manufacturing company

    tax jurisdiction dispute

    is quicken 2013 a Sino foreign joint venture enterprises, the registered capital of 56000000 dollars. 2 foreign shareholders of the http://quicken2013formac.devhub.com/ company (registered including Bermuda and the Mauritius Republic) signed a "sale and purchase agreement", from one side to buy another party's share of the company's equity, the transaction completed in Japan, according to the agreement, the transfer of stock rights will yield 8130000 the dollar.

    China issued a new "enterprise income tax law" third paragraph third: "non resident enterprise has http://quickbooks2013-download.webs.com/ no establishment, in places, or has an organization, its income by the institutions, places no actual connection, the source in the territory shall pay enterprise income tax." Although the company 2 enterprises transfer of shares are foreign non resident enterprises, and transfer behavior in overseas, but because the transfer of the resident enterprise within the territory of China shares, foreign enterprises have the source of equity investment assets transferred quicken 2013 to the territory of the income should be invested enterprises located in the payment is paid, the IRS District of Tanggu city.

    however, as foreign companies to transfer party put forward, because it is registered in the Mauritius Republic, according to the tax agreement of thirteenth with the Mauritius Republic on the proceeds of property, the transfer of property income should be applicable to other property of fifth "the transfer of the first paragraph to paragraph fourth outside the property gains only in the transfer, for the taxation of the resident country of". In the Republic of Mauritius customs, and submit the proof of identity of the Republic of Mauritius residents, asking for agreement. Investigators IRS

    Tanggu District in carefully study Mao agreement, that need to confirm the foreign investors in the holding shares in the company during the period of carrying on immovable total assets ratio is up to 50%, if 50%, fourth transfer agreement "a company of shares in the capital of the revenue, the company's property directly or indirectly principallyof is located in a contracting state real quicken property, may be taxed in the Contracting State", has the right to tax. If not up to 50%, only applicable agreement fifth, imposed by the Republic of Mauritius. Investigators immediately. "</p>

    Posted 12 years ago #

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