The Taxes And Interests Of Clothing Trade Enterprises Were Successfully Warehoused In Shenzhen Luohu District National Taxation Bureau

Recently, the first foreign investment in China clothing The tax payment and interest of 13.96 million yuan for the investigation of anti tax avoidance of commercial enterprises were successfully warehoused in Shenzhen Luohu District National Taxation Bureau.

According to reports, M Company is a wholly foreign-owned trading subsidiary headquartered overseas, mainly engaged in clothing wholesale and retail business. In 2011, he applied to Luohu District National Taxation Bureau to pay a huge service fee to the overseas parent company, and claimed exemption of non resident enterprise income tax on the ground that the labor service occurred overseas. The tax administrator found in the audit that the management services related to the contract agreements were not only numerous, but also only related to the management functions of the parent company to the subsidiary rather than professional management services, so it was inferred that Company M was suspected of fabricating or falsely increasing the service fees to transfer profits.

The survey found that there were long-term related purchase and sales transactions and a large number of related services between M Company and its parent company, which inflated costs and transferred high profits to achieve tax avoidance. The anti tax avoidance working group gradually found out the same kind of enterprises through on-site inspection of the office space and business stores of M Company, special study and discussion of the company's financial system software, review and analysis of its related declaration materials and financial data, and visit and investigation of many business enterprises in Shenzhen Clothes & Accessories The business characteristics of the trade industry and the trend of industrial chain management. In the face of detailed data and careful analysis, Company M finally admitted that it had unreasonable connected transactions, which led to losses for consecutive years.

In view of the wide variety of clothing sold by M Company, strong seasonality and no major products, and its brand operation mode is quite different from that of domestic clothing trade enterprises, in comprehensive consideration of the functions and risks undertaken by the company in the group's operation After the factors such as marketing intangible assets formed by helping the group to promote its brand in the Chinese market and the resulting group operating cost saving effect, Luohu District State Taxation Bureau decided to use the profit split method to divide the profit of related party transactions between Company M and the parent company.

"Recently, the company has paid a total of 13.96 million yuan of corporate income tax and interest to the warehouse. Next, the Luohu District State Administration of Taxation will carry out a five-year follow-up management. According to preliminary estimates, the tax impact on M Company during this period will reach 30 million yuan." The relevant person in charge of the Luohu District State Administration of Taxation told reporters.