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近年来,非居民以无形资产投资入股的案例成倍增长,其中存在一定比例的虚高作价,由此衍生出被投资企业的税前列支、非居民持股比例的确定、非居民企业的股权转让所得确认等税收问题,对税务机关加强后续管理带来了困难。一、无形资产虚高作价入股的现实背景无形资产投资入股不是新事物,但近几年却增长迅速,这背后有其现实背景。首先,《公司法》的修订为无形资产投资虚高入股拓展了空间。新《公司法》取消了公司货币出资不得低于注册资本30%的限
In recent years, non-resident investment in intangible assets in the case of shares doubled, of which there is a certain percentage of imaginary price, which derive from the taxable branches of invested enterprises, the proportion of non-resident shares held by non-resident enterprises Equity transfer income tax issues such as confirmation, the tax authorities to strengthen follow-up management has brought difficulties. First, the actual situation of the intangible assets imaginary cost shares Intangible assets investment shares is not new, but in recent years has grown rapidly, which has its background behind the reality. First of all, the revision of the “Company Law” expands the space for inflating the intangible assets into shares. The new “Company Law” to cancel the company’s capital contribution of not less than 30% of the registered capital limit