2023合伙制私募股权基金应税所得分配方法研究报告

Group 1 - The core viewpoint of the report is the exploration of taxable income distribution methods for partnership private equity funds in China, emphasizing the need for improved tax compliance and regulatory clarity [1][9][17] - The development of private equity funds in China began in 1985, and as of June 2022, the market size reached 19.97 trillion yuan, indicating significant growth and increasing concentration of capital among leading institutions [1][22] - The partnership structure, primarily limited partnerships, is favored due to its flexibility in establishment and tax benefits, avoiding double taxation [1][25] Group 2 - Tax policies for partnership funds follow the "distribute first, tax later" principle, where the fund itself does not pay taxes, and partners are taxed based on their individual or corporate income tax rates [2][38] - Practical challenges include discrepancies between tax and accounting profits, cash flow mismatches, and disputes over distribution ratios, which can lead to unfair tax burdens on partners [3][4][39] - A proposed method for taxable income distribution is the "cash flow restoration method," which simulates cash flow distribution to partners while considering costs and adjusting for different cash flow stages [5][9] Group 3 - Recommendations for policy improvements include clarifying tax rules for partnership funds, enhancing information reporting mechanisms, and optimizing tax administration practices to reduce operational ambiguities [6][7][8] - The report concludes that the current tax distribution practices are outdated and need to align with market practices to ensure fair tax burdens among partners [9][17]