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Suggestions on enterprise income tax reform

The mining economy occupies an important strategic position in the whole national economy, and at the same time, it has the characteristics of high investment and high risk, which requires that certain preferential policies be given to mining enterprises in terms of taxation, especially the preferential policies for enterprise income tax, which can better mobilize the enthusiasm of capital investment in mining resources development industry and improve industry efficiency. However, China's original income tax policy contains relatively little support for technological innovation and environmental protection in mineral resources mining industry, which is insufficient to promote technological innovation, extend industrial chain and improve the level of environmental governance and protection in mineral resources mining industry, and lacks policy support for the transformation of mineral resources exhausted areas, which restricts the sustainable development of China's mining economy.

compared with foreign countries, China's original enterprise income tax restricts the sustainable development of mining economy in the following concrete ways: first, foreign countries include mineral resources reserves assets in the cost according to production depletion (that is, resource depletion allowance), while China's mineral resources reserves are not treated as assets; Second, there are also some specific regulations on the treatment of exploration and development expenses abroad. In the mining contract, the treatment methods, amortization period and amortization rate of various expenses should be listed in detail. Some regulations are more favorable, such as the exploration expenses are deducted as costs once after mining, and the development expenses are deducted in principle in the year when they occur, but the original enterprise income tax in China has no preferential treatment in this regard; Third, most countries allow mining enterprises to adopt methods such as accelerated depreciation, initial depreciation and depreciation with appreciation, which has also become an important means of tax-based tax reduction and exemption, while there are no specific provisions on accelerated depreciation, initial depreciation and depreciation with appreciation in China.

in January p>28, China began to implement a new Enterprise Income Tax Law of the People's Republic of China. In the new enterprise income tax, the preferential policies related to the sustainable development of mining economy mainly include: the special funds for environmental protection and ecological restoration extracted by enterprises in accordance with the relevant provisions of laws and administrative regulations are allowed to be deducted; The expenses incurred by enterprises engaged in the exploitation of mineral resources such as oil and natural gas before the start of commercial production and the methods for depreciation and depreciation of fixed assets shall be separately stipulated by the finance and taxation departments of the State Council; For special equipment such as environmental protection, water saving and energy saving, and safe production that meet the requirements, 1% of the investment of the special equipment can be credited from the tax payable of the enterprise in the current year; If the credit is insufficient in that year, it can be carried forward in the next five tax years.

in view of the provisions of the new enterprise income tax law on mining economy, the author thinks that the new enterprise income tax should expand the preferential scope of encouraging innovative activities and resource-saving behaviors in the detailed implementation rules. The most important preferential measures for mining projects are embodied in some preferential measures in the early stage, especially the tax treatment of exploration and development expenditure (accelerated depreciation, extra deduction, capitalization, current amortization, etc.), exhaustion subsidy, interest deduction, tax reduction and exemption, loss carry-over clause and tax deferred payment, etc., so as to reflect the time value of tax revenue. The specific reform measures mainly include the following points:

(1) Mining enterprises are allowed to spend on mineral exploration, feasibility study and mine development. Allow the mine to accelerate depreciation, and the equipment will be depreciated in 5 ~ 7 years; Give preferential income tax deduction to the research and development expenditures of mining enterprises related to environmental protection; Losses arising from the exploitation of mineral resources can be carried forward in a longer period of time to offset taxable income.

(2) tax incentives are given to capital investment used by mining enterprises to improve mining recovery rate, mineral processing recovery rate, comprehensive utilization rate, energy saving and raw material saving, and relevant taxes are reduced or exempted for mines with declining income.

(3) It is clearly stipulated that mineral resources mining enterprises can withdraw the safety fund and allow it to be deducted before tax together with environmental protection projects. In view of the fact that mineral resources mining enterprises owe a lot of money on safety investment and environmental protection investment, the extraction standard of funds should be appropriately raised to encourage enterprises to increase safety and environmental protection investment.

(4) Implement tax incentives to support technological progress. First, for special equipment that meets the requirements of environmental protection, water saving and energy saving, safe production, etc., the credit amount can be appropriately increased and the credit period can be extended accordingly; If the credit is insufficient in that year, it can be carried forward in the next five tax years. The second is to support deep processing projects of resources. For deep processing projects of resources that can be accounted for separately, tax concessions of "two exemptions and three reductions" are given to promote efficient and rational utilization of resources.