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关联企业之间进行无息借款会涉及哪些税务问题呢?
Sou Hu Cai Jing· 2025-04-27 13:16
Group 1 - The issue of value-added tax (VAT) arises when related enterprises engage in interest-free loans, as these are treated as "loan services" subject to VAT [2] - According to the announcement from the Ministry of Finance and the State Taxation Administration, inter-company interest-free loans within a corporate group are exempt from VAT until December 31, 2027 [2] - There is a risk of tax liabilities if related enterprises do not meet the criteria of a corporate group, as they may not qualify for the VAT exemption [2] Group 2 - There is a risk of special tax adjustments under the Corporate Income Tax Law, where tax authorities can adjust taxable income based on independent transaction principles [3] - Interest expenses incurred by the lending party may not be deductible if the borrowing party uses bank loans to lend to related parties, leading to tax adjustments [3] Group 3 - Generally, non-financial enterprises are not required to pay stamp duty on loan contracts between companies [4] - If one party in the loan agreement is a financial company established by a corporate group, stamp duty must be paid on the loan contract [4] - Companies must be cautious of VAT and corporate income tax adjustments when engaging in interest-free loans between related enterprises, and should conduct tax planning based on corporate group qualifications and tax law requirements [4]