Group 1 - The core concept of financial product transfer involves the transfer of ownership of foreign exchange, securities, non-commodity futures, and other financial products [2] - Other financial products include various asset management products such as funds, trusts, and wealth management products, as well as various financial derivatives [2] - The sales amount for financial product transfer is determined by the balance after deducting the purchase price from the selling price, with any positive or negative differences offset against each other [2] Group 2 - The time of tax obligation for taxpayers engaged in financial product transfer occurs on the day of ownership transfer [3] - Certain financial product transfer incomes are exempt from value-added tax, including transactions by qualified foreign institutional investors (QFII) and Hong Kong market investors through specific channels [4] - Financial product transfers cannot issue special value-added tax invoices [4] Group 3 - The relevant policies are outlined in the notice from the Ministry of Finance and the State Administration of Taxation regarding the comprehensive implementation of the pilot program for the conversion of business tax to value-added tax [4]

Core Viewpoint - The article discusses the implications of value-added tax (VAT) on financial asset transactions during debt restructuring, highlighting the potential tax risks for companies involved in such transactions [2]. Group 1: Debt Restructuring Case - On June 5, 2024, Company A and Company B signed a debt restructuring agreement where Company A used its debt instrument investment in Company C to repay a debt of 15 million yuan owed to Company B [3]. - Company A recognized the financial asset used for repayment at a book value of 10 million yuan, with a fair value of 9.5 million yuan, and calculated the VAT on the transaction as 1.8 million yuan [3][6]. - Company B, upon receiving the financial asset, recorded it as a debt investment at a value of 9.5 million yuan and recognized an investment income of 5.48 million yuan [4][8]. Group 2: VAT Treatment for Seller - According to the regulations, the transfer of financial products falls under the scope of financial services, with a VAT rate of 6% applicable to general taxpayers [5]. - Company A's calculation of VAT on the transfer of financial products was confirmed to be correct, applying the appropriate tax rate [5]. - The correct VAT calculation for Company A was adjusted to 1.7 million yuan based on the formula for determining sales revenue [6]. Group 3: VAT Treatment for Buyer - The regulations state that financial product transfers cannot issue special VAT invoices, requiring the issuance of regular VAT invoices instead [7]. - Consequently, Company B could not deduct input VAT and included the VAT amount in the cost of the financial asset, resulting in a debt investment amount of 9.5 million yuan [7][8].