Workflow
新型融资模式税务风险
icon
Search documents
提示:新型融资模式税务风险增加
Sou Hu Cai Jing· 2025-06-24 10:30
Core Viewpoint - The article discusses the increasing tax risks associated with new financing models, specifically asset-backed securities and joint ventures with repurchase obligations, highlighting how companies may exploit these structures to reduce taxable income [3][4]. Financing Models and Tax Risks - In 2024, the total social financing scale increased by 32.3 trillion yuan, with a year-end stock of 408.3 trillion yuan, reflecting an 8% growth compared to the previous year [3]. - Companies are using asset-backed securities to package accounts receivable into bonds, which are sold at a discount, allowing them to recognize investment income while improperly deducting interest expenses [5][6]. - The joint venture model involves companies paying "equity maintenance fees" to secure the right to purchase shares, which are treated as financial expenses, leading to potential tax deductions [11][12]. Case Studies - Company A issued 1.8 billion yuan in asset-backed securities, recognizing a 324 million yuan investment income while improperly deducting the same amount as a loss [8][10]. - Company B, through a joint venture, paid equity maintenance fees calculated based on the total investment, which were fully deducted for tax purposes, raising questions about their classification as interest expenses [12][14]. Regulatory Considerations - The article emphasizes the need for companies to adhere to accounting standards that require the recognition of financial assets based on the actual risks retained, which may not align with their current practices [9][13]. - Tax regulations stipulate that interest expenses must not exceed the rates applicable to financial institutions, which could limit the deductibility of fees paid in these financing arrangements [14].