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Whether corporate income tax is payable by issuing shares to purchase assets?

Yes

If a listed company acquires assets (equity) through private placement of shares, the transferor of the assets (equity) can be regarded as investing in the listed company with assets (equity). According to the "Financial Finance The Notice of the State Administration of Taxation on Corporate Income Tax Policies for Non-monetary Asset Investments (Caishui [2014] No. 116) stipulates that the transferor may, within a period of no more than 5 years, evenly include the income from the transfer of the asset (equity) in installments. The taxable income in the corresponding year shall be calculated and paid corporate income tax in accordance with regulations. The assessed value of assets (equities) acquired by listed companies is used as the tax basis.

If a listed company acquires more than 50% of the assets (equity) of the target enterprise through private placement, according to the "Notice of the Ministry of Finance and the State Administration of Taxation on Several Issues Concerning the Treatment of Enterprise Income Tax on Enterprise Reorganization Business" (Finance and Taxation [2009] No. 59) According to the provisions of the "Notice of the Ministry of Finance and the State Administration of Taxation on the Treatment of Corporate Income Tax on Promoting Enterprise Restructuring" (Caishui [2014] No. 109), if the share payment ratio in the acquisition is not less than 85% of the total transaction amount, and the actual business continuity is achieved, , the requirements for continuity of shareholder rights and reasonable business purposes, and with the continued existence of equity and operations in the target enterprise, special tax treatment can be selected: the asset (equity) transferor does not temporarily recognize income, and the tax on the additional shares obtained The basis is determined based on the original tax basis of the transferred assets (equity). The tax base of the assets (equity) acquired in the private placement of listed companies is recognized based on the original tax base.