As a financial investor, if there is a cash-out plan after the company goes public, then before the listing, it is best for the listed company to use a direct structure, that is, the natural person directly holds the equity of the listed company, rather than the holding company's shareholding, which not only facilitates the withdrawal, but also saves the part of corporate income tax that the holding company needs to bear when selling shares in the future, and only needs to pay its own personal income tax.
If the shareholder intends to hold the equity of a listed company for a long time, it is not for the purpose of cashing out. It is suggested to adopt a three-tier equity structure of natural person-holding company-company to be listed. Because the tax law stipulates that dividends obtained by resident enterprises from resident enterprises enjoy tax-free treatment. This can avoid the tax burden caused by dividends.
Turn some shareholders of the company into limited partnerships. Especially for Internet enterprises with high value-added rate, enterprises are likely to directly increase their value by 10 or even 20 times in a short period of time. Therefore, limited partnership should be considered from the beginning, and the most direct benefit is to avoid repeated taxation.
Secondly, for example, if the company wants to encourage employees' equity, and the actual controller does not want employees to hold shares directly, but wants to be a shareholding platform, then the shareholder should consider becoming a limited partnership. However, in some areas, such as Shenzhen, just three days ago, the income tax preference for limited partnerships was abolished, and the provisional 20% tax rate was restored to the progressive tax system of 5-35%. Then, for the shareholders of the company with an actual increase of more than 10 times, the reduction will be extremely bad.
It is also because China's tax system is different from that of European and American countries, and it is taken away when it is profitable. When you lose money, the money will not be returned to you. At most, you can use the loss to defer income tax and deduct it in the next few years, but there are quite a few restrictions. Therefore, it is a rational choice for many investment companies to register in Tianjin Binhai, Tibet and other tax depressions in order to avoid taxes reasonably and legally to the maximum extent.