反避税

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非上市股份公司将资本公积用定向增发给一个股东,个人股东涉及到个税吗?
Sou Hu Cai Jing· 2025-07-18 13:24
对于反避税,虽然我国的税法规定还不严密,但是实务中却一直在做并且近年来逐步在加强。从近年来 税务局公布的各类有关个人所得税稽查案例,其实都是在执行反避税措施,比如严查影视明星、网红主 播等通过"转换收入性质偷税"。 非上市股份公司将资本公积用定向增发给一个股东,个人股东涉及到个税吗? 非上市股份公司,用账面上所有股东的资本公积给其中一个法人股东(企业)定向增发(不需要另外出 钱),个人股东是否涉及个人所得税? 解答: 提问所述虽然用了一个看着"高大上"的名词——定向增发,但是依然掩盖不了非上市公司的个人股东向 法人(企业)股东转移股权(股份)的事实。 假如A股份有限公司(非上市),法人(企业)股东甲公司占有50%股份,个人股东张三、李四、王五 等诸多人员合计占有50%。按照提问所述进行一番"定向增发"操作,A股份有限公司的资产、负债和所 有者权益总额都没有发生变化,只是所有者权益内部结构以及股东的股份比例发生了变化,比如股东甲 公司股份变成了70%,诸多个人股东变成30%。 这些个人股东为什么要同意呢?——他们没有傻吧? 当然没有傻!——因为A股份有限公司分红的话,这些个人股东就要缴纳20%的股息红利所得的个 ...
新关税环境下,国际税收规则变化与企业出海税务案例分享
梧桐树下V· 2025-06-15 07:31
Core Viewpoint - The article discusses the challenges and opportunities for Chinese companies in the context of increasing overseas investments amid geopolitical tensions and complex tax regulations, emphasizing the need for systematic tax risk management capabilities [1]. Group 1: Event Overview - The event titled "Tax Risk Inspection and Tax Planning for Enterprises Going Abroad" will be held on June 21, 2025, in Shenzhen, organized by Wutong Classroom in collaboration with Qirui Feng [1]. - The training aims to address the complexities faced by Chinese enterprises in overseas investments, including geopolitical games, tax system differences, and international anti-avoidance regulations [1]. Group 2: Course Details - The course will cover international tax frameworks, common tax risks for outbound enterprises, and tax optimization strategies [10][11][12]. - The training schedule includes a morning session from 9:00 to 12:00 and an afternoon session from 14:00 to 17:00, followed by a Q&A session [4]. Group 3: Course Fees and Registration - The course fee is set at 1280 yuan per person, with a mid-year discount price of 780 yuan per person, which includes course materials but excludes travel, meals, and accommodation [5]. - Registration can be completed by scanning a QR code or contacting the organizer for inquiries [7]. Group 4: Course Content - The course will cover key topics such as international tax principles, common tax risks in outbound investments, and strategies for tax optimization [10][11][12]. - Specific areas of focus include investment structure design, permanent establishment risks, transfer pricing risks, and tax treaty abuse risks [13][14]. Group 5: Learning Outcomes - Participants will learn to identify core risk points in cross-border investments, prevent anti-avoidance risks, optimize global tax structures, and enhance dispute resolution capabilities [17][18].
2025年BVI公司最新申报新规及公司注册与维护详解
Xin Lang Cai Jing· 2025-05-26 05:05
Core Points - The BVI government has implemented new regulations effective January 2, 2025, aimed at enhancing transparency and compliance in the international financial center [1] - Companies are required to maintain detailed records of their shareholder registers and beneficial ownership information to combat money laundering and tax evasion [1] Group 1: Shareholder Register Requirements - Companies existing before January 2, 2025, must submit their shareholder register by June 30, 2025 [3] - New BVI companies must submit their shareholder register within 30 days of registration, and any changes in shareholder information must be updated within 30 days [3] - Exemptions from the shareholder register requirement apply to companies listed on recognized stock exchanges, certain investment funds, and incubator or approved funds [4][5] Group 2: Beneficial Ownership Information - Companies must submit beneficial ownership information to the registry, with the same deadlines as the shareholder register [6][7] - The definition of a beneficial owner includes individuals who own or control 10% or more of the shares or voting rights of a company [8] - Exemptions for beneficial ownership information submission are similar to those for the shareholder register, including companies listed on recognized exchanges and certain fund types [10] Group 3: Penalties for Non-Compliance - Companies that fail to submit the required shareholder register and beneficial ownership information by the deadlines will face fines starting at $600 for the first three months, increasing to $800 for the next three months, and potential deregistration thereafter [11]