企業(yè)全球化之布局與租稅管理(編輯修改稿)
2024-11-15 10:12 本頁面
【文章內容簡介】 g its own resources in these activities, it would be entitled to a mensurately higher anticipated return from the activity and the conditions of the transaction would be different from when the distributor acts merely as an agent, being reimbursed for its costs and receiving the ine appropriate to that activity. Similarly, a contract manufacturer or a contract research provider that takes on no meaningful risk would be entitled to only a limited return. 17 柒、 固定營業(yè)場所 (Permanent Establishment / Fixed Place of Business) ?從事全球化佈局及租稅規(guī)劃管理須注意固定營業(yè)場所可能產生的租稅問題。 ?在當地建立固定營業(yè)場所 (實質上 )，即可能產生當地來源所得，而有稅務申報問題 . ?請參看我國所得稅法第 10條 ,有關固定營業(yè)場所的規(guī)定 . 捌、有效管理供應鏈的稅賦 Tax Effective Supply Chain Management (TESCM) 19 捌、有效管理供應鏈的稅賦 ? Many multinationals seek to reanize their supply chain to: – reduce costs。 – increase revenue。 and – improve customer service through the costeffective management of materials and products through all business processes. 20 捌、有效管理供應鏈的稅賦 (續(xù) ) ? The overriding business driver behind recent largescale supply chain management (“SCM”) projects has been the realization of petitive advantage through the coordination of purchasing, production, sales, distribution, logistics, Ramp。D and customer services on a global or regional basis. 21 捌、有效管理供應鏈的稅賦 (續(xù) ) ? From a taxation perspective, SCM on a global or regional integrated basis facilitate the replacement of the traditional countrybased tax structures with a Hubco tax structure centered around a principal which performs as many of the integrated SCM functions as possible. The full risk manufacturers and distributors are converted into toll processors (consignment contract manufacturers) or contract manufacturers, and limited risk distributors (“LRD”) or marketing/sales support entities. 22 捌、有效管理供應鏈的稅賦 (續(xù) ) Buy materials Manufacturer Inventory risks Warranty risk Intangibles Capital investment Title to goods Working capital Buy finished goods Distributor Inventory risk Warranty risk Intangibles Title to goods Pricing risk Volume risk Credit risk Single source dependen
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