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Can the housing maintenance fund paid by the company to the Housing Authority be deducted before tax?

a: the notice of State Taxation Administration of The People's Republic of China on enterprise income tax related to real estate development (Guo shui fa [23] No.83) (note: this article has been abolished at present) stipulates that real estate development enterprises are responsible for the maintenance, repair and replacement of * * * used parts and * * used facilities and equipment of sold development products in accordance with relevant laws, regulations or contracts.

The Notice of State Taxation Administration of The People's Republic of China on the Collection of Enterprise Income Tax for Real Estate Development Business (Guo Shui Fa [26] No.31) stipulates that if the development enterprise transfers the * * * used parts and * * used facilities and equipment maintenance funds that have been included in the sales income to the relevant departments and units according to regulations, it shall be deducted at the time of transfer. The maintenance fund withheld and withheld shall not be deducted.

according to the spirit stipulated in the two documents, it should be understood that the enterprise's own withholding but not yet used cannot be deducted before tax, but only the actually used part (the part that has been spent or handed over) can be deducted.