According to the Notice of the Ministry of Finance of State Taxation Administration of The People's Republic of China on Comprehensively Promoting the Pilot Work of Changing Business Tax to Value-added Tax (Caishui [2065438+06] No.36) and Annex 3 Provisions on the Transition Policy of Changing Business Tax to Value-added Tax, "1. The following subjects are exempted from value-added tax: ..... (19) Interest income. 7. In the unified borrowing and repayment business, the interest charged by enterprise groups or core enterprises within enterprise groups and financial companies affiliated to the group shall not be higher than the loan interest rate paid to financial institutions or the coupon rate level of bonds paid.

If the interest charged by the unified borrower to the fund user is higher than the loan interest rate paid to the financial institution or the coupon rate level of the bonds paid, the value-added tax shall be paid in full.

Unified borrowing and unified return business refers to:

(1) After an enterprise group or a core enterprise in an enterprise group borrows money from a financial institution or issues bonds to foreign countries to obtain funds, it distributes the borrowed funds to subordinate units (including independent accounting units and non-independent accounting units, the same below), and collects the repayment of the principal and interest of the financial institution or bond purchaser from the subordinate units.

(2) After an enterprise group borrows money from a financial institution or issues bonds abroad to obtain funds, the financial company to which the group belongs signs a unified loan contract with the enterprise group or its subordinate units and allocates funds, and after collecting principal and interest from the enterprise group or its subordinate units, it is transferred to the enterprise group, and the enterprise group uniformly returns the business of the financial institution or the bond purchaser. "