在不改变现有利益格局下，为社保体系提供相对稳定的收入来源。 2日，财政部、税务总局公开《关于划转充实社保基金国有股权及现金收益运作管理税收政策的通知》 （下称《通知》），明确划转充实社保基金国有股权及现金收益免征相关的增值税、企业所得税和印花 税等。这一税收优惠政策执行日期追溯至2024年4月1日。 为此，一个值得尝试的方案是受益/收益权划转模式，即可考虑除国有股权直接产权划转外，尝试将待 划转的国有股权打包成资产收益权和受益权，并划归社保的模式，或将待划转国有股权实现由普通股向 优先股划转。 这样做的利好因素在于：首先，可有效打开国有资本划转社保基金的上限，如可无需考虑现有10%国有 股权划转的上限问题，从而不至于对国有企业的治理结构、董事会构成结构等人事和经营管理等产生影 响，因为按照现有的国有资本划转方式，若一个国企的国有股权划转触及公司法、证券法的重大披露要 求，那么尽管在所有权属上并不涉及实控人的实质变化，但会在治理形式上带来一些复杂变化。 不论是通过资产证券化只向社保基金划转国有资本受益权和收益权，还是将待划转的国有资本转为优先 股进行划转，都有助于降低国有资本划转社保的摩擦成本，缓解由此带来的不 ...

Core Viewpoint - The Ministry of Finance and the State Taxation Administration have issued a notification to implement four tax exemption measures to support the transfer and management of state-owned equity and cash income for the social security fund, effective from April 1, 2024 [1][2]. Tax Exemption Measures - The first measure exempts value-added tax on all interest and interest-like income from loans and financial product transfer income obtained by the receiving entities during the investment process of transferred state-owned equity and cash income [2]. - The second measure classifies income from the transfer of state-owned equity and cash income as non-taxable income for corporate income tax purposes [3]. - The third measure exempts the stamp duty that the receiving entities should pay when transferring non-listed state-owned equity [4]. - The fourth measure implements a "first collect, then return" policy for stamp duty on the transfer of listed state-owned equity and on securities transactions using cash income [4]. Impact on Investment Dynamics - The tax incentives are expected to enhance the net income space for receiving entities, thereby increasing their investment returns and encouraging them to diversify their asset allocation beyond traditional low-risk assets [5]. - The measures are anticipated to transform the social security fund into a long-term institutional investor in the capital market, promoting a shift from short-term speculation to long-term value investment [5]. Policy Significance - The notification signals a commitment to stabilize expectations, promote reforms, and support the market by reducing investment costs for receiving entities, thereby injecting long-term capital into the market [5]. - The policy aims to address the sustainability of the basic pension insurance system amid increasing aging population pressures and to enhance public confidence in the social security system [5]. Historical Context - The transfer of state-owned capital to supplement the social security fund is a significant initiative by the central government, aimed at addressing the pension fund shortfall by transferring 10% of state-owned equity from major enterprises and financial institutions [7]. - The operational framework for managing the cash income from these transfers has been established, with a focus on market-oriented and professional management principles [8].