金融资产(C公司债务工具投资)

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债务重组中,用金融资产偿债如何缴纳增值税
Sou Hu Cai Jing· 2025-08-08 17:15
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].