非上市公司股权转让个人所得税计税依据研究
发布时间：2018-09-13 09:55
【摘要】：个人转让非上市公司股权不存在交易价格或者交易价格不合理情况时应由税务人员核定组成计税价格计征个人所得税，在具体的操作中主要是以每股净资产或转让股权对应份额的净资产值来核算股权转让收入，这势必会低估股权转让收入，造成非上市公司股权转让个人所得税的少征漏征。为防止个人转让非上市公司股权的个人所得税款流失，促进税收征管效率，提升税收公平，本文提出一种简单易操作的适用于核定征收时的股权转让定价方法，用以核定股权转让收入，确定计税依据。 该定价法以行业为研究对象，以同行业内不同企业的资产有相同的盈利能力为假设前提，从上市公司的流通股入手，测算各行业上市公司流通股的每股净资产溢价率，求得上市公司行业平均净资产溢价率，，然后通过嵌入非流通性折扣因素，推导出上市公司非流通股行业净资产溢价率，同时将其作为非上市公司行业净资产溢价率，并以此为基础确定非上市公司股权转让计税价格。最后根据所转让的份额是否构成控制权的转移，决定是否将控制权溢价包含在组成计税价格之内。通过案例检验，分析出估算值与实际值产生差异的原因后，提出个人转让非上市公司股权核定征收方法下，个人所得税计税依据核定方法及计算公式。
[Abstract]:In the event that there is no transaction price or unreasonable transaction price for the transfer of the shares of an unlisted company by an individual, the taxable price shall be determined and taxed by the tax officer to collect the individual income tax, In the specific operation, the net asset value of net assets per share or corresponding share of equity transfer is used to calculate the income from equity transfer, which will certainly underestimate the income from equity transfer, resulting in the undercollection and omission of individual income tax on equity transfer in non-listed companies. In order to prevent the loss of personal income tax, to promote the efficiency of tax collection and management and to promote tax fairness, this paper proposes a simple and easy to operate method for the transfer pricing of shares when it is approved and collected. Used to approve the income from equity transfer and determine the tax basis. This pricing method takes the industry as the research object, taking the same profitability of different enterprises in the same industry as the premise, starting with the circulating shares of the listed companies, calculates the net asset premium per share of the listed companies in various industries. The average net asset premium rate of listed companies is obtained, and then the net asset premium rate of non-tradable shares industry is deduced by embedding non-circulation discount factors, which is regarded as the net asset premium rate in non-listed companies industry. And on this basis to determine the non-listed company equity transfer tax price. Finally, according to whether the transferred share constitutes the transfer of control, it is decided whether to include the control premium in the constituent tax price. After analyzing the reasons of the difference between the estimated value and the actual value, this paper puts forward the method of personal income tax calculation based on the approved method and the calculation formula.
【学位授予单位】：暨南大学
【学位级别】：硕士
【学位授予年份】：2012
【分类号】：F812.42;F832.51
本文编号：2240844
[Abstract]:In the event that there is no transaction price or unreasonable transaction price for the transfer of the shares of an unlisted company by an individual, the taxable price shall be determined and taxed by the tax officer to collect the individual income tax, In the specific operation, the net asset value of net assets per share or corresponding share of equity transfer is used to calculate the income from equity transfer, which will certainly underestimate the income from equity transfer, resulting in the undercollection and omission of individual income tax on equity transfer in non-listed companies. In order to prevent the loss of personal income tax, to promote the efficiency of tax collection and management and to promote tax fairness, this paper proposes a simple and easy to operate method for the transfer pricing of shares when it is approved and collected. Used to approve the income from equity transfer and determine the tax basis. This pricing method takes the industry as the research object, taking the same profitability of different enterprises in the same industry as the premise, starting with the circulating shares of the listed companies, calculates the net asset premium per share of the listed companies in various industries. The average net asset premium rate of listed companies is obtained, and then the net asset premium rate of non-tradable shares industry is deduced by embedding non-circulation discount factors, which is regarded as the net asset premium rate in non-listed companies industry. And on this basis to determine the non-listed company equity transfer tax price. Finally, according to whether the transferred share constitutes the transfer of control, it is decided whether to include the control premium in the constituent tax price. After analyzing the reasons of the difference between the estimated value and the actual value, this paper puts forward the method of personal income tax calculation based on the approved method and the calculation formula.
【学位授予单位】：暨南大学
【学位级别】：硕士
【学位授予年份】：2012
【分类号】：F812.42;F832.51
【引证文献】
相关期刊论文 前1条
1 郭杰;;完善非上市公司个人股权转让税制的思考[J];财会月刊;2013年10期
本文编号：2240844
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