China: 降低增值税率最终目的是刺激消费带动生产,企业关注重点在对现金流的

Last Updated: 8 April 2019
Article by DeHeng Law Offices
Most Read Contributor in China, August 2019

摘要:

增值税税率下降之所以是对企业的重大利好,主要是因为税率下降减少了企业的经营现金流出,进而企业可以用节省下来的资金合理安排销售政策和投资、筹资政策,为企业或股东、社会创造更多的价值。

近日,财政部、税务总局、海关总署联合发布了《关于深化增值税改革有关政策的公告》(财政部税务总局海关总署公告2019年第39号),将今年《政府工作报告》中提出的将原适用16%增值税税率(主要是生产型企业适用)应税行为的税率降至13%,并于4月1日起施行。这无疑是对生产型企业的重大利好,但同时产生了一个税收利益在增值税链条中如何分配的问题。类似"税率降3%,客户要求降价3%是否合理"的文章就得到了不少点击量,但部分文章内容却具有一定的误导性。

下表根据某文章举例编制:

注:降价3%后的销售价格=120*(1-3%),降税率后的利润增长率=(17.4-16.8)/16.8*100%,降价3%的利润增长率=(14.268-16.8)/16.8*100%。

文章拟通过上例说明,税率下降提升企业利润,但与税率同比降价将导致利润大幅下降,两者无法完全对冲。此观点符合一般民众"我真金白银交税,赚到手的钱当然就少"的朴素逻辑,结论也无重大错误,其主要瑕疵在于,按照一般人的理解在计算利润时将增值税作为一项支出进行了扣除。因为从理论上讲,增值税是通过层层抵扣由最终消费者负担的,企业只是在销售时代国家收取,并不属于企业所得。所以,无论在财务还是税务上,增值税一般情况下不属于计算利润或企业所得税应税所得时的扣除项目。增值税影响企业利润或企业所得税应税所得是通过城市维护建设税和教育费附加(税金及附加)实现的。

续前例,在不考虑其他因素的情况下,税率下降及降价对营业利润的影响如下表所示:

注:计算销项税额和进项税额时应当扣除价格中所含的增值税税款,城市维护建设税税率为7%、教育费附加费率为3%,未考虑地方教育附加。

可见,增值税税率下降,对企业利润的提升非常有限,但降价对企业利润的影响则较大。

增值税税率下降之所以是对企业的重大利好,主要是因为税率下降减少了企业的经营现金流出,进而企业可以用节省下来的资金合理安排销售政策和投资、筹资政策,为企业或股东、社会创造更多的价值。利润在权责发生制会计原则下往往只是纸面富贵,由于受赊销等销售政策的影响,当期利润经常并未实际收取现金,转变为企业的现金流入。而按我国增值税税制,销项税额计算以权责发生制为原则,进项税额则要凭票抵扣,造成就某笔销售业务而言企业在未收到现金的情况下,却要拿出现金缴税,给企业造成现金流上的压力。增值税税率下降,可以说是国家对企业的输血。

现实情况要复杂得多,企业是否降价将利好传递给最终消费者,不是单一因素所能决定的,要看企业进销价格的弹性(价格变动对进销量的影响)、应收账款周转率(销售与收款时间上的趋同性)、企业在增值税链条中的地位、投融资能力、企业风险偏好等因素,在进行科学测算的基础上作出合理决策。

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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