【正文】 許扣除稅的速度 快 于資產(chǎn)經(jīng)濟(jì)價(jià)值的下降 ?應(yīng)納稅所得額獲準(zhǔn)流動(dòng)確認(rèn)的速度比現(xiàn)金資產(chǎn)經(jīng)濟(jì)價(jià)值 增加慢 ?特別稅的評(píng)估 ?稅收扣除允許的速度 低于 經(jīng)濟(jì)資產(chǎn)價(jià)值的 下降 ? 應(yīng)納稅所得額獲準(zhǔn)認(rèn)可的速度 快 于資產(chǎn)在經(jīng)濟(jì)現(xiàn)金流的 增加 值 稅收籌劃作為有利 的活動(dòng)應(yīng)該以這樣的方式設(shè)計(jì)，這樣可以使貿(mào)易在額外收入和稅收費(fèi)用之間可以實(shí)現(xiàn)最終的稅后回報(bào)率達(dá)到最大化 。例如， 對(duì)進(jìn)行集中管理還是分散管理作出決策，開一個(gè)分店還是建立一個(gè)子公司，從本地供應(yīng)商購還是國外供應(yīng)商購買資源，分配股息還是保持實(shí)力，通過發(fā)行股票還是發(fā)行債券籌集資金，是遣返還是 再投資附屬公司（跨國公司的案件），謹(jǐn)慎地估計(jì)，稅收是一個(gè)最有影響力的因素之一。任何規(guī)定的漏洞可能被利用就像稅的漏洞，利用它是有利益的（例如，計(jì)算的漏洞‘損失頭下資本收益’可以用來顯示沒有一個(gè)資本損失，而不能設(shè)置抵銷額外收入）。 但是，為了計(jì)劃和戰(zhàn)略的成功，同樣需要財(cái)政會(huì)計(jì)的背景、金融和經(jīng)濟(jì)規(guī)則。W依基瑞 .柯勒會(huì)計(jì)詞典 . 新德里：印度霍爾私人有限公司 .1984. 3. 國際會(huì)計(jì)準(zhǔn)則 (IASB) (2021)，國際金融報(bào)告準(zhǔn)則（ 2021） .倫敦：國際會(huì)計(jì)準(zhǔn)則“國際會(huì)計(jì)準(zhǔn)則（ ISA） 12，所得稅” 721780. 4. 瓊斯 M， S羅茲 卡塔那西 .：預(yù)先戰(zhàn)略 .紐約： McGrawHill 國際公司 . 5. Lakhotia, R. N, S. Lakhotia. .新德里：視覺出版社 . 6. 經(jīng)濟(jì)合作與發(fā)展組織 . ：經(jīng)濟(jì)合作與發(fā)展組織 . 7. 帕爾基瓦拉 A， B帕爾基瓦拉 .1976. 帕爾基瓦拉的法律和所得稅慣例 卷一 .孟買： N. M. Tripathi 有限公司。M . 21 世紀(jì)英語詞典 .新德里：聯(lián)合議院（印度）有限公司 . , A, M. G. Gurha. . 阿拉哈巴德：現(xiàn)在法律機(jī)構(gòu)。M . .香港： Macmillan 出版有限公司 . 9 Tax Planning in Business: Bangladesh Perspective Swapan Kumar Bala, FCMA Associate Professor Department of Accounting amp。 vide Wilkinson, 1992: 2). Planning is “the process of determining in advance the factors necessary to achieve a set of goals。 2. deduct tax at source where it is necessary。 4. file returns in time。 and 6. be aware of legal remedies where it does not have its rights under the law recognized. Tax function activities of a business entity are those activities which are concerned with fiscal issues. These functions are of two types: (1) tax pliance activities, and (2) tax planning activities. Tax pliance activities are those activities which include the functions or obligations according to the provisions of various fiscal statutes. Tax planning activities means dealing with the tax matters of a taxpayer with a view to maximizing the aftertax rate of return on investments after ensuring voluntary tax pliance. FORMS OF BUSINESS VS. TAX PAYING ENTITY A business entity may be of three types: soleproprietorship, partnership firm and pany. “Sole proprietorship” has not been defined by the Ine Tax Ordinance. Under section 2(32) of the ITO, “firm” has the same meaning as assigned to it in the Partnership Act, 1932 (IX of 1932). Under section 4 of the Partnership Act, 1932, “Partnership” is the relation between persons who have agreed to share the profits of a business carried on by all or any of them acting for all. 10 Persons who have entered into partnership with one another are called individually “partners” and collectively “a firm”, and the name under which their business is carried on is called the “firm name”. Under section 2(20) of the ITO, “pany” means a pany as defined in the Companies Act, 1913 (VII of 1913) or Companies Act, 1994 (Act No. 18 of 1994)* and includes – (a) a body corporate established or constituted by or under any law for the time being in force。 (bb) an association or bination of persons, called by whatever name, if any of such persons is a pany as defined in the Companies Act, 1913 or Companies Act, 1994。 and。 (2) Other panies: (a) Company not publicly traded。 (b) The pany is enlisted with the Stock Exchange before the end of the concerned ine year in which ine tax assessment will be made. Taxpayer’s Status: Under the Ine Tax Ordinance, 1984, a taxpayer has two types of status: personal status and residential status. A soleproprietorship has no separate tax paying identity and individual owner running the soleproprietorship will have “Individual” status of the owner and not of the business entity, but both partnership firm and pany have distinct personal status – “Firm” and “Company” respectively. Residential status may be resident [defined u/s 2(55), ITO] or non resident [defined u/s 2(42), ITO]. Under section 17, resident assessee (taxpayer) has to pay ine tax on total global ine including foreign ine, but nonresident taxpayer has to pay ine tax only on his total domestic (Bangladeshi) ine as determined u/s 18 (ine deemed to accrue or arise in Bangladesh). Under section 2(55), an individual is to be a resident if his period of stay in Bangladesh is at least 182 days in the concerned ine year, or at least 90 days in the concerned ine year, and at least 365 days in the preceding 4 ine years. A partnership firm is considered as resident, if the control and management of its affairs situated wholly or partly in Bangladesh in the concerned ine year. A pany will be a resident, if control and management of its affairs situated wholly in Bangladesh in the concerned ine year. Otherwise, a taxpayer will be treated as nonresident [u/s 2(42)]. Levels of Taxation: Question regarding whether the entity itself and/or the owner(s) of the entity is(are) taxable is explained on the basis of two concepts: passthrough entity (or flowthrough entity) and nonpassthrough entity: ? PassThrough Entity: This entity is not taxable itself. The ine of the entity will pass through the owners and is taxable after its accumulation with the owner?s other ine. Sole proprietorship is a passthrough entity. The owner of the entity is taxable for the entire ine of the business entity (whether withdrawn or not) along with his/her other ine. 11 ? NonPassThrough Entities: This entity is taxable itself. The ine of the entity may be distributed to the owners and is usually again taxable in the hands of owners after its accumulation with his/her other ine. Partnership firm and pany are nonpassthrough entities. A partnership firm is taxable for its ine in first instance as a nonpassthrough entity. The partners of the firm shall include the share of total ine of the firm in the ine year [to be puted u/s 43(3)] and but to avoid double taxation, the share of ine will be treated as taxfree ine subject to “tax rebate at average tax rate (ATR)” if the firm has already