A: According to Article 51 of the Regulations for the Implementation of the Enterprise Income Tax Law of the People's Republic of China, "The public welfare donation mentioned in Article 9 of the Enterprise Income Tax Law refers to the donation made by enterprises to public welfare undertakings stipulated in the Public Welfare Donation Law of the People's Republic of China through public welfare social organizations or people's governments at or above the county level and their departments". The group's affiliated enterprises donated money for Wenchuan earthquake relief, and donated it through the county civil affairs bureau. It fully meets the conditions of public welfare donation and belongs to public welfare donation. According to Article 53 of the Regulations: "The public welfare donation expenses incurred by enterprises that do not exceed12% of the total annual profits are allowed to be deducted." Donations from enterprises affiliated to this group are allowed to be deducted within the standard of not exceeding the total profit in 200812%. According to Article 1 (2) of the Notice on Seriously Implementing Tax Policies for Earthquake Relief and Post-disaster Reconstruction issued by the Ministry of Finance and State Taxation Administration of The People's Republic of China (2008) No.62, "Public welfare donations made by enterprises are allowed to be deducted when calculating and paying income tax according to the provisions of the Enterprise Income Tax Law and its implementing regulations". According to the spirit of this document, there is no special provision for donations made by enterprises affiliated to this group for earthquake relief, and public welfare donations12% are still deducted.

According to the above provisions, the author formulates the following tax planning scheme.

Scheme 1: Donation by Enterprise A alone.

1.Allowable deduction standard1200,000 yuan.

In 2008, the total profit of enterprise A is expected to be10 million yuan, and some public welfare donations within12%12 are allowed to be deducted, and the allowable deduction standard is1200,000 yuan.

Allowable deduction standard =1000x12% =120 (ten thousand yuan)

2. It is not allowed to deduct part of 800,000 yuan.

Public welfare donation1200,000 yuan is allowed to be deducted before income tax, and the rest shall not be deducted.

No deduction allowed = 200-120 = 80 (ten thousand yuan)

3. The increased tax burden is 200,000 yuan.

The non-deductible public welfare donation is 800,000 yuan. According to the new enterprise income tax law, the enterprise income tax rate is 25%, which increases the tax burden by 200,000 yuan.

Increased tax burden = 80× 25% = 20 (ten thousand yuan)

In addition to donating 2 million yuan, enterprise A has to pay 200,000 yuan in corporate income tax, so the group needs to actually pay 2.2 million yuan.

Option 2, donated by enterprise B alone.

1.The deduction standard is 960,000 yuan.

In 2008, enterprise B is expected to realize a total profit of 8 million yuan, and some charitable donations within12% are allowed to be deducted. The allowable deduction standard is 960,000 yuan.

Allowable deduction standard = 800 x12% = 96 (ten thousand yuan)

2. It is not allowed to deduct part of1040,000 yuan.

Public welfare donation of 960,000 yuan is allowed to be deducted before income tax, and the rest shall not be deducted.

No deduction allowed = 200-96 =104 (ten thousand yuan)

3. The increased tax burden is 260,000 yuan.

Non-deductible public welfare donation/kloc-0.04 million yuan, according to the new enterprise income tax law, the enterprise income tax rate is 25%. This increased the tax burden by 260,000 yuan.

Increased tax burden =104x25% = 26 (ten thousand yuan)

In addition to donating 2 million yuan, enterprise B has to pay 260,000 yuan in corporate income tax, so the group needs to actually pay 2.26 million yuan.

Option 3] Donations will be made by both enterprises.

1.Enterprise A donates within the allowable deduction standard, and the rest is donated by Enterprise B..

(1) Enterprise A donated1200,000 yuan.

In 20 12 years, the estimated total profit of enterprise A is10 million yuan, and the public welfare donations within12% are allowed to be deducted. The allowable deduction standard is1200,000 yuan, and the actual donation of enterprise A is1200,000 yuan, so the full deduction is allowed without paying income tax:

(2) Enterprise B donated 800,000 yuan.

In 20 12, the estimated total profit of enterprise B is10 million yuan, and the part of public welfare donation within12% is allowed to be deducted. The allowable deduction standard is 960,000 yuan, and the actual donation of enterprise B is 800,000 yuan, which is allowed to be fully deducted without paying income tax.

As a result, the group doesn't need to pay any additional taxes except that two enterprises, A and B, donate 2 million yuan together.

2. Enterprise B donates within the allowable deduction standard, and the rest is donated by Enterprise A..

(1) Enterprise B donated 960,000 yuan.

In 20 12, the estimated total profit of enterprise B is 8 million yuan, and the part of public welfare donations within12% is allowed to be deducted. The allowable deduction standard is 960,000 yuan, and the actual donation of enterprise B is 960,000 yuan, which is allowed to be fully deducted without paying income tax.

(2) Enterprise A donated1040,000 yuan.

In 20 12 years, the estimated total profit of enterprise A is10 million yuan, and the part of public welfare donation within12% is allowed to be deducted. The allowable deduction standard is1200,000 yuan, and the actual donation of enterprise A is10.04 million yuan, which is allowed to be fully deducted without paying income tax.

As a result, the group doesn't need to pay any additional taxes except that two enterprises, A and B, donate 2 million yuan together.

3. Enterprises A and B donate within their respective allowable deduction standards, and the total amount donated by both parties is 2 million yuan, which will not increase the tax burden of the group. The reason is the same as above.

According to the above analysis: Scheme 1, in addition to donating 2 million yuan, the group has to pay 200,000 yuan in income tax; Option 2: In addition to donating 2 million yuan, the group has to pay 260,000 yuan in income tax; Option three. Apart from donating 2 million yuan, the group does not have to bear any income tax. Obviously, Option 3 is undoubtedly the best choice for this group.