According to this regulation, if the capital increase of non-monetary assets does not meet the special tax treatment conditions of Caishui No.200959, the investor shall recognize the income in the current period, that is, it shall be regarded as sales and shall pay enterprise income tax.
In addition, State Taxation Administration of The People's Republic of China document 2000 1 18 stipulated that foreign investment with non-monetary assets exceeding 50% of the taxable income of investors can be included in the taxable income on average for five years. According to AnnouncementNo. 19 of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC) (20 10), unless otherwise stipulated by the Ministry of Finance of People's Republic of China (PRC) and State Taxation Administration of The People's Republic of China, all income from property transfer shall be paid in full, so the unified tax payment for five years is cancelled.
Therefore, accounting treatment:
Borrow: Long-term investment-RMB 50 million from Company B.
Loan: Long-term investment-6,543,800,000 yuan from Company C.
The investment income is 40 million yuan
Tax treatment:
Assess the capital increase of 40 million yuan, and confirm that the income will be calculated and paid as investment income in the current year.