Workflow
特别纳税调整
icon
Search documents
【关注】企税汇缴结束后,“特别纳税调整应税所得”需调整,相关要点看这里!
蓝色柳林财税室· 2025-07-28 01:31
Group 1 - The article discusses the principle of independent transactions, emphasizing that transactions between unrelated parties should adhere to fair market prices and business norms to ensure proper tax compliance [3] - It highlights the issue of unreasonable pricing in related party transactions, where the pricing deviates significantly from market norms, leading to potential tax adjustments by tax authorities [4][7] - Various transfer pricing methods are outlined, including comparable uncontrolled price method, resale price method, cost-plus method, transactional net margin method, and profit split method, which are used to assess and adjust related party transaction pricing [7] Group 2 - The article addresses capital weakening, where companies increase debt capital while reducing equity capital to lower taxable income through deductible interest expenses [8] - It specifies the debt-to-equity ratio standards set by tax laws, indicating that exceeding these ratios may result in non-deductible interest expenses, necessitating adjustments to taxable income [8] - The concept of controlled foreign corporations is introduced, where profits from foreign entities controlled by domestic companies, which are not distributed or are minimally distributed, may need to be included in the domestic company's taxable income [9]