The difference between processing with supplied materials and processing with supplied materials
One is trade. Feed processing is a trade way for export enterprises to buy raw materials from abroad with foreign exchange and re-export them after production and processing; Processing with supplied materials is a trade method in which foreign businessmen provide certain raw materials or technical equipment, and export enterprises process and assemble them as required, and charge processing fees for finished products. The second is risk. Foreign exchange for feed processing occupies working capital and bears the quality of export commodities and export risks; Processing with supplied materials does not occupy capital, nor does it consider the risks existing in sales. The third is property rights. Feed processing has the ownership of products, and the trade relationship between export enterprises and foreign businessmen is buying and selling. Processing with supplied materials does not own the ownership of products, and the relationship between export enterprises and foreign businessmen is entrusted and entrusted. The fourth is taxation. The self-operated or entrusted export goods production enterprises shall be exempted from VAT credit and tax refund, and their taxable consumer goods shall be exempted from consumption tax. Foreign trade enterprises shall be exempted from VAT or refunded first, and their taxable consumer goods shall be refunded consumption tax. Export goods processed with imported materials are exempt from value-added tax and consumption tax, and labor remuneration income of processing enterprises is exempt from value-added tax and consumption tax. The input tax paid for domestic raw materials consumed by export goods shall not be deducted and transferred to the production cost, and the tax paid for domestic supporting raw materials shall not be refunded.
Comparison and Analysis of Tax Policies
In processing trade, the proportion of imported materials, the difference of tax rate and export price will affect the choice of imported materials or processing methods for export enterprises. Under the same conditions, the focus is on the difference of tax burden (regardless of income tax factors).
(a) the size of the difference between the tax rate and the tax rebate rate
According to the provisions of the tax law, the products obtained by multiplying the export income by the difference between the tax rate and the tax rate should be included in the main business cost. Under the premise of a certain export income, the greater the difference in tax rates, the higher the cost tax burden that export enterprises have to bear.
For example, a production-oriented export enterprise A processes a batch of goods for foreign businessman B, and the price of converting imported bonded materials into RMB is 20 million yuan, and the total price of converting the processed goods into RMB is 35 million yuan (all documents are received). Assuming that all the goods are not exported for domestic sales, the input tax of materials and other expenses purchased in China is 700,000 yuan, the applicable tax rate of value-added tax is 17%, and the export tax rebate rate is 13%, try to analyze whether it is more appropriate for export enterprises to choose raw material processing or raw material processing.
1. Processing with supplied materials: 35 million yuan of export goods are tax-free, 700,000 yuan of input tax is not deducted and the expenses are borne by itself, and the taxable amount is 700,000 yuan.
2. Feed processing: 35 million yuan of export goods will be exempted from tax refund, and 20 million yuan of imported materials will not be refunded, which will be deducted when calculating the tax refund exemption.
Current period when tax reduction or exemption is not allowed = FOB price of export goods × RMB foreign exchange quotation × difference of tax refund rate of export goods-price of duty-free purchased raw materials × difference of tax refund rate of export goods = (3500-2000) × (17%-13%) = 600 (ten thousand yuan).
Taxable amount in current period = output tax amount-(input tax amount-tax exemption and refund in current period is not reduced) =0-(70-60)=- 10 (ten thousand yuan)
Current tax exemption = FOB export goods (all documents have been received) × foreign exchange RMB quotation × export goods tax rebate rate-price of duty-free purchased raw materials × export goods tax rebate rate = (3500-2000) ×13% =195 (ten thousand yuan).
Then the tax refund is 654.38 million yuan, and the tax exemption is 1.85 million yuan. If the tax allowance is considered to participate in the calculation of urban maintenance and construction tax and education surcharge (hereinafter referred to as tax), then the tax is 10000 yuan.
Judging from the above assumptions, the tax payable of the export enterprises that adopt the feed processing method is zero, and they only pay the tax of 1 10,000 yuan, and the tax burden is less than the tax payable for the processing with supplied materials.
Assuming that the original tax rebate rate 13% is reduced to 5% and the feed processing method is adopted, then:
Tax relief in this period = (3500-2000) × (17%-5%) =180 (ten thousand yuan)
Tax payable in this period = 0-(70-180) =110 (ten thousand yuan)
Current tax exemption =(3500-2000)×5%=75 (ten thousand yuan)
The tax allowance is 750,000 yuan, and the tax has been paid 1 10,000 yuan. If feed processing is adopted, the tax burden will be lighter than that of feed processing.
(2) What is the proportion of imported materials and parts?
Under the feed processing mode, the value-added tax of domestic consumables directly affects the calculation of tax.
Extending the above example, if the input tax of domestic materials consumption is increased to 900,000 yuan, and the taxable amount of imported materials is reduced to 6,543,800 yuan, then:
Tax relief in this period = (3500-1500) × (17%-13%) = 80 (ten thousand yuan)
Tax payable in this period =0-(90-80)=- 10 (ten thousand yuan)
Current tax exemption = (3500-1500) ×13% = 260 (ten thousand yuan)
The tax refund is 654.38 million yuan, the tax exemption is 2.5 million yuan and the tax payment is 250,000 yuan. In the case of processing with imported materials, the tax payable is 700,000 yuan, and the tax burden is greater than 250,000 yuan paid by processing with imported materials.
On the contrary, if the input tax on domestic materials consumption is reduced to 654.38+10,000 yuan and the taxable value of imported materials is increased to 30 million yuan, then:
Tax relief in this period = (3500-3000) × (17%-13%) = 200 (ten thousand yuan)
Tax payable in this period =0-( 10-20)= 10 (ten thousand yuan)
Current tax refund exemption =(3500-3000)× 13%=65 (ten thousand yuan)
The tax allowance is 650,000 yuan, and the tax has been paid 1 10,000 yuan. For example, under the processing mode, the tax payable is 654.38+10,000 yuan, and the tax burden is less than the processing tax payable 1 10,000 yuan.
(3) the price of export commodities.
Extending the above case, in the feed processing mode, if the export price is raised to 50 million yuan, then:
Tax relief in this period = (5000-2000) × (17%-13%) =120 (ten thousand yuan)
Tax payable in this period =0-(70- 120)=50 (ten thousand yuan)
Current tax refund exemption =(5000-2000)× 13%=390 (ten thousand yuan)
The tax allowance is 3.9 million, and the tax paid is 390,000. For example, under the processing mode, the tax payable is 700,000 yuan, and the tax burden is less than 890,000 yuan.
On the contrary, if the export price is reduced to 25 million yuan, then:
Tax relief in this period = (2500-2000) × (17%-13%) = 200 (ten thousand yuan)
Tax payable in this period =0-(70-20)=-50 (ten thousand yuan)
Current tax refund exemption =(2500-2000)× 13%=65 (ten thousand yuan)
The tax refund is 500,000 yuan, the tax exemption is 6.5438+0.5 million yuan, and the tax is 1 10,000 yuan. For processing with materials, the tax payable is 70, and the tax burden is greater than the tax payable for processing with materials 10000 yuan.
Choice and benefit
To sum up, the choice of processing trade must consider the above three conditions, and find out the best mode of operation.
(1) When the consumption of imported materials for export goods is small, and the difference between taxation and tax refund rate is small, it is more appropriate to choose the feeding processing method. Because the amount of imported materials to be deducted for tax refund is relatively small, the actual tax refund amount should be relatively large. In addition, if the difference between the tax rate and the tax refund rate is small, the input tax will be transferred out less, which will easily lead to tax refund.
(2) When the export goods consume a lot of imported materials, and the tax rate and tax refund rate are quite different, it is more appropriate to choose the processing method with supplied materials. Because the duty-free processing of incoming materials has nothing to do with the difference between tax collection and tax refund, and the larger the imported materials, the less the materials consumed in China, the smaller the non-deductible part of the input tax, and the less the tax burden, so there is no fund for purchasing imported materials. In contrast, the amount of tax that cannot be exempted and deducted in the current feed processing period will become larger, and sometimes the phenomenon of tax payment that is not sold domestically will be formed.