Management difficulties of non-trade foreign exchange payment

Since 65438+1 March 19991implemented the provision of "submission of tax vouchers for non-trade foreign exchange payments", there are still some difficulties in tax management of non-trade foreign exchange payments:

Domestic enterprises are not clear about the tax-related items of non-trade foreign exchange payment. According to many enterprise managers, in the past, it was enough to go directly to the bank to pay foreign exchange. I didn't expect to go to the tax department at all, and I didn't know that I would have to pay if I didn't fulfill my obligations. The tax clauses of some foreign-related contracts of China enterprises are vague and simple. The tax obligation is not clear, and even the tax obligation that should be borne by the foreign party is taken on itself; Enterprises don't take the initiative to fulfill the obligation of withholding and remitting, and their work coordination is negative. Judging from the reporting situation of taxable enterprises, only13 of taxable enterprises voluntarily declare non-trade foreign exchange payment tax; Tax authorities and bank management departments have different judgments on whether some projects belong to the scope of non-trade certificates. For example, banks believe that the purchase of export quotas and other businesses are non-trade payment of foreign exchange, while tax authorities believe that such businesses are normal transactions and do not need to issue certificates, and so on. For some specific expenses, it is difficult to grasp how the tax authorities locate tax exemption. For example, overseas enterprises and institutions carry out quality and safety certification for domestic enterprises, and domestic enterprises have to pay a so-called certification maintenance fee, annual inspection fee and testing fee every year. In order to improve the national foreign exchange management and tax administration, State Taxation Administration of The People's Republic of China promulgated Huifa [2008] No.64 (Notice on Issues Related to the Submission of Tax Certificates for Foreign Payment of Service Trade and Other Projects), distinguishing whether different foreign exchange payment projects need payment certificates and which institutions need to audit tax certificates.

A big challenge faced by multinational companies, as pointed out in the report of Platinum Consulting, the largest financial and taxation experience sharing platform for multinational companies in China, the following problems have become a big challenge in the work of its Linked-F members (that is, the financial and taxation manager of WOFE):

1. What are the payment methods and how to work out the best payment plan?

2. What is the key point for the tax bureau to check the foreign exchange payment tax payment vouchers of enterprises?

3. How to understand foreign exchange payment from the economic background and management habits of multinational enterprises?