Tobacco Allocation Stations Still Have Room For Tax Planning (1)

In the past, because the cigarette consumption tax was levied in the industrial sector, that is, the tax paid on the basis of the ex factory price of cigarettes was paid for the consumption tax. Therefore, many cigarette manufacturers set up an independent cigarette allocation Station for the purpose of reducing the consumption tax.

Tobacco factories sell cigarettes to pfer stations at a lower price, the consumption tax is calculated at this price, and the pfer stations are sold at a higher price, thereby reducing the consumption tax.

This is a common way for many tobacco factories to circumvent consumption tax.

In June of this year, the state issued the notice on adjusting the consumption tax policy on tobacco products (fiscal 2001 [91]), and made a major adjustment to the cigarette consumption tax policy: the consumption tax rate was adjusted from a single proportional tax rate to a fixed tax rate and a proportional tax rate. The fixed duty rate was 150 yuan per standard box, and the proportional tax rate was 45% of the allocation price of more than 50 yuan, 30% below 50 yuan.

The tax assessment method is changed from ad valorem rating to compound tax calculation method which combines quantity quota and ad valorem rating.

In other words, the production and sale of cigarettes, first of all, according to the sales volume of 150 yuan per box of fixed consumption tax, and then according to the allocation price of a fixed rate of consumption tax.

People in the industry generally agree that the purpose of this policy adjustment is to prevent enterprises from avoiding tax by setting up a pfer station.

The price of the ad valorem rate is based on the allocation price of the cigarettes or the price approved by the tax authorities. The price is not the factory price, but the price of the cigarette paction concluded by the cigarette factory through the cigarette market and the buyer, and it is finally determined by the State Administration of Taxation.

From above, we can see that the feasibility of circumvention consumption tax through pfer stations is also very small.

Is there any need for allocation stations? This is a problem that many cigarette factories are concerned about at present.

According to the insiders, from the perspective of reducing corporate income tax, the planning method of setting up pfer stations is still feasible, but the purpose is not to lower the consumption tax burden, but to lower the corporate income tax burden.

As we all know, most tobacco companies have always made good profits, and they have become a multi industry group company. They pay a lot of corporate income tax. At the same time, with the intensification of competition in the cigarette market, although cigarettes can not be advertised, cigarette factories pay a lot of advertising fees to promote the visibility of enterprises and take the overall image of the enterprises.

Therefore, there is a phenomenon that three fees are greatly exceeded and not deducted before income tax.

The existence of pfer stations can share part of the above expenses, thereby playing a role in reducing corporate income tax.

The basic practice is that the group company makes the image advertising and business propaganda independently according to the sales volume; the pfer station also makes the image advertising and business propaganda independently according to its sales sales, and the two sides disburse the image advertising fee and the business publicity fee independently.

An example is analyzed as follows: it is assumed that a group cigarette factory did not set up an independent pfer station in 2000. Its sales revenue of cigarettes was 2 billion 200 million yuan, its image advertising cost was 53 million yuan, its advertising expenses were 20 million 500 thousand yuan, and its entertainment expenses were 5 million 100 thousand yuan.

According to the provisions of the pre tax deduction method of enterprise income tax, the advertising fee can meet the deduction standard, and the deductible amount is 2% of the sales revenue. The advertising cost of the cigarette factory can be deducted from 44 million yuan (220000 x 2%) and overspend 9 million yuan (5300-4400). The business entertainment fee can be deducted: the portion of the sales fee is 5 5 of sales income, more than 3 parts per thousand, so the deductible limit is 6 million 630 thousand yuan, the actual expenditure is 5 million 100 thousand yuan, it can be deducted in full, and the business promotion fee is deducted from the standard sales income of 6 million 630 thousand%, so in fact, it can deduct the quota to be RMB $($2%) and overspend RMB.