我国企业所得税减免对企业境外并购的影响研究

发布时间：2018-08-16 13:58

【摘要】：中国加入WTO已有15年的时间,在此期间,经济全球化不断加深,中国经济迅速发展,发展模式也从单纯的“引进来”逐步转变为成熟的“走出去”。宏观环境的驱动、内在需求增长以及“一带一路”战略的实施,都为国内外经济联动带来了积极的推动作用。近年来,中国企业在境外并购增长迅速,企业境外并购受多方面因素的影响,税收虽然不是企业境外并购的主要原因,但是税收成本却是交易主体必须考虑的问题,所以,如何最大可能的利用现有的税收优惠政策降低企业境外并购的成本以及带来更多的税后利润必将成为企业实施并购行为所要考虑的重要一环。税收政策作为国家宏观调控的重要手段,能够合理的引导资源优化配置。基于税收政策尤其是其中与并购最为密切的企业所得税对企业境外并购的重要性,以及中国企业在境外并购面临多方面挑战的情况,进一步完善企业所得税制度,不仅可以更好的实现税收筹集财政收入这一职能,更是促进新经济发展时期我国企业顺利“走出去”的重要手段。本文主要采取“理论+模型”的研究方法,阐述了企业境外并购过程中以及并购后我国企业所得税的相关规定,在借鉴国外相关研究的基础上,通过模型推导论证企业所得税对境外并购的数量以及金额的影响,进一步通过公式讨论免税法、扣除法以及抵免法对企业投资的税收激励作用。最后,结合相关理论与当前现状,提出完善我国企业所得税制度、提高税收征管服务水平、加强国际间税务合作等建议,为我国企业境外并购保驾护航,为我国“走出去”的企业提供税收政策支持。
[Abstract]:It has been 15 years since China joined the WTO. During this period, the economic globalization is deepening, the Chinese economy is developing rapidly, and the development mode has been gradually changed from a simple "introduction" to a mature "going out". The driving force of macro environment, the growth of internal demand and the implementation of "Belt and Road" strategy have brought positive impetus to the domestic and foreign economic linkage. In recent years, Chinese enterprises have been increasing rapidly in overseas mergers and acquisitions, and overseas mergers and acquisitions of enterprises have been affected by many factors. Although tax is not the main reason for overseas mergers and acquisitions, but the tax cost is a problem that must be considered by the main parties of transactions, so, How to make the most of the existing preferential tax policies to reduce the cost of overseas mergers and acquisitions and bring more after-tax profits will become an important part of the implementation of mergers and acquisitions. As an important means of national macro-control, tax policy can reasonably guide the optimal allocation of resources. In view of the importance of tax policies, especially the enterprise income tax, which is most closely related to mergers and acquisitions, to overseas mergers and acquisitions, as well as the fact that Chinese enterprises are facing many challenges in overseas mergers and acquisitions, the enterprise income tax system has been further improved. It is not only better to realize the function of tax revenue raising, but also an important means to promote Chinese enterprises to "go out" smoothly in the period of new economic development. This article mainly adopts the "theoretical model" research method, elaborated the enterprise overseas merger and acquisition process as well as after the merger and acquisition our country enterprise income tax related stipulation, in the reference foreign correlation research foundation, The influence of enterprise income tax on the amount and amount of overseas M & A is discussed through the model derivation, and the tax incentive effect of tax exemption method, deduction method and credit law on enterprise investment is discussed through formula. Finally, according to the relevant theories and current situation, the paper puts forward some suggestions, such as perfecting our country's enterprise income tax system, improving the level of tax collection and management service, strengthening international tax cooperation, and so on, in order to protect our country's enterprises from overseas mergers and acquisitions. To provide tax policy support for our country's "going out" enterprises.
【学位授予单位】：广东外语外贸大学
【学位级别】：硕士
【学位授予年份】：2017
【分类号】：F812.42;F271

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