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“融资难”是当下众多企业面临的窘境,除了银行贷款、发行债券和股权融资等方式外,民间借贷成了破解资金周转困难“短平快”的手段。债权人为了规避借出资金的财务风险,使出种种解数:要求债务人提供保证人以增加还款信用;要求债务人提供财产抵押、质押以获取担保物权;签订以融资为目的的混合性投资和售后回购合同;等等。近期,笔者遇到一件以融资为目的的股份回购案例,税企双方对如何进行税务处理产生争议。本文结合此案例,对“售后回购”
“Financing Difficulties ” is the dilemma faced by many enterprises nowadays. Apart from bank loans, bond issuance and equity financing, non-government borrowing and lending has become a solution to the problem of cash flow difficulties, “short and flat fast”. In order to avoid the financial risk of lending funds, creditors resorted to various solutions: requiring the debtor to provide a guarantor to increase repayment credit; requiring the debtor to provide property mortgages and pledges to obtain security interests; signing a hybrid investment for the purpose of financing and after-sale repurchase Buy contract Recently, I encountered a case of share repurchase for the purpose of financing, tax and business sides on how to deal with tax controversy. This article combined with this case, the “sale repurchase ”