Thuế TNDN Từ Kinh Doanh

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Luật Thuế thu nhập doanh nghiệp số 14/2008 được thông qua ngày 3/6/2008
Nghị định 124/2008/NĐ-CP ngày 11/12/2008
Thông tư số 130/2008/TT-BTC ngày 26/12/2008

Những điểm đáng lưu ý về Luật Thuế TNDN áp dụng từ ngày 1/1/2009

I. Người chịu thuế
• Tổ chức:
o Doanh nghiệp được thành lập và hoạt động theo các Luật VN;
o Các tổ chức;
o Đơn vị sự nghiệp;
o Tổ chức khác có hoạt động kinh doanh có thu nhập.
• Cá nhân:
o Cá nhân và nhóm cá nhân kinh doanh;
o Hộ kinh doanh cá thể;-Cá nhân hành nghề độc lập;
o Cá nhân cho thuê tài sản.
• Các Luật VN: Luật Doanh nghiệp, Luật DNNN, Luật đầu tư nước ngoài, Luật Đầu tư, Luật các tổ chức tín dụng, Luật kinh doanh bảo hiểm, Luật chứng khoán, Luật Dầu khí, Luật Thương mại.
• Luật nước ngoài (PE hoặc non PE)
• Các văn bản pháp luật khác
• Hình thức: Công ty, DNTN, các bên trong HĐ HTKD, xí nghiệp liên doanh dầu khí, JOC, đơn vị sự nghiệp công lập, tổ chức theo Luật HTX…
• “Người chịu thuế” thay cho “đối tượng nộp thuế”
• Bỏ “đối tượng không thuộc diện nộp thuế” (tức “người không chịu thuế”)

II.Thu nhập chịu thuế
• Thuật ngữ:
o Thu nhập chịu thuế
o Thu nhập được miễn thuế
o Thu nhập tính thuế

Thuế TNDN phải nộp = TN tính thuế X Thuế suất
Thuế TNDN phải nộp=(TN tính thuế -Phần trích lập qũy KH&CN) X T.suất
TN tính thuế = TN chịu thuế – TN miễn thuế – lỗ năm trước chuyển sang

1.Thu nhập chịu thuế: tổng các loại thu nhập chịu thuế
– Thu nhập từ hoạt động kinh doanh
– Thu nhập khác : gồm 20 loại
– Thu nhập từ hoạt động kinh doanh bất động sản ( đã bao gồm ở thu nhập khác)
• Nguyên tắc hòa nhập của các loại thu nhập:
– Thu nhập lãi và thu nhập lỗ: lựa chọn
– Thu nhập từ BĐS: không hòa nhập với các loại thu nhập khác( kể cả từ kinh doanh) và có chế độ chuyển lỗ riêng
– Thu nhập hưởng chế độ ưu đãi thuế.
2.Thu nhập được miễn thuế
– Thu nhập từ trồng trọt, chăn nuôi, nuôi trồng thủy sản của HTX.
– Thu nhập từ thực hiện dịch vụ kỹ thuật trực tiếp phục vụ nông nghiệp
– Thu nhập từ nghiên cứu khoa học và phát triển công nghệ, sản phẩm trong thời kỳ sản xuất thử. Thời gian tối đa không quá 1 năm.
– Thu nhập từ hoạt động dành riêng cho người khuyết tật, sau cai nghiện, nhiễm HIV (bình quân 51% trong tổng số lao động bình quân trong năm).
– Thu nhập từ dạy nghề cho người dân tộc thiểu số, người khuyết tật, trẻ em khó khăn, đối tượng tệ nạn xã hội.
– nhập được chia từ hoạt động góp vốn, mua CP, liên doanh, liên kết với DN trong nước (sau khi thu nhập này đã chịu thuế).
– Khoản tài trợ cho giáo dục, nghiên cứu KH, VH-NT, từ thiện, nhân đạo và hoạt động xã hội khác tại VN à nếu sử dụng không đúng mục đích thì chịu thuế với thuế suất 25%.
3. Thu nhập tính thuế

Thu nhập tính thuế=TN chịu thuế – TN miễn thuế-Lỗ năm trước chuyển sang
Thu nhập chịu thuế=TN từ SXKD hànghóa,D.vụ + Các thu nhập khác
Thu nhập từ SXKD hàng hóa, dịch vụ=Doanh thu – Chi phí được trừ

• Doanh thu để tính thu nhập chịu thuế và nguyên tắc ghi nhận doanh thu không thay đổi
• Thời điểmđể xác định doanh thu:
o Hàng hóa: chuyển giao quyền sở hữu, quyền sử dụng
o Dịch vụ: hoàn thành dịch vụ hoặc thời điểm lập hóa đơn
o Bất động sản: thời điểm bàn giao (có áp dụng chế độ tạm thu trước thuế TNDN khi thanh toán).
• Chi phí được trừ:
o Bỏ thuật ngữ “chi phí hợp lệ”
Cách thức xác định:
* Thỏa mãn nguyên tắc là chi phí
* Không thuộc các khoản không được trừ đã liệt kê. Không xuất hiện “các khoản chi không được trừ khác”
Nguyên tắc để được xem là chi phí được trừ khi xác định thu nhập chịu thuế:
o “Khoản chi thực tế phát sinh liên quan đến hoạt động sản xuất, kinh doanh của DN”
o “Khoản chi có đủ hóa đơn, chứng từ theo qui định của pháp luật”
o Bỏ: “Các khoản chi do nguồn kinh phí khác đài thọ”.
4. Thu nhập khác: Có 20 loại thu nhập khác, trong đó lưu ý:
• Thu nhập từ chuyển nhượng vốn, chuyển nhượng chứng khoán
• Thu nhập từ chuyển nhượng bất động sản
• Bổ sung: chênh lệch do đánh giá lại tài sản theo qui định để góp vốn , để điều chỉnh tài sản khi hợp nhất, chia, tách, sáp nhập, chuyển đổi loại hình DN, trừ trường hợp đánh giá TSCĐ khi chuyển DNNN thành Cty CP.
• Bổ sung: tiền đền bù về TSCĐ trên đất và tiền hỗ trợ di dời sau khi trừ các chi phí liên quan. Riêng tiền đền bù và tiền hỗ trợ di dời của DN theo qui định của Nhà nước thì theo qui định của pháp luật liên quan.
• Bổ sung: Khoản nhận bằng tiền hoặc hiện vật từ các nguồn tài trợ trừ tài trợ để sử dụng cho giáo dục, nghiên cứu khoa học, văn hóa, nghệ thuật, từ thiện, nhân đạo và hoạt động xã hội khác tại VN.
5. Các quy định bổ sung :
– DN phải đăng ký phương pháp khấu hao trước khi trích khấu hao. Trong năm DN được điều chỉnh mức trích khấu hao trong mức qui định, sau đó phải điều chỉnh đăng ký chậm nhất vào nộp quyết toán.
– Khi chia, tách, hợp nhất, sáp nhập, chuyển đổi loại hình có đánh giá lại TSCĐ theo qui định thì được tính khấu hao theo nguyên giá đánh giá lại.
– TSCĐ tự làm nguyên giá là tổng chi phí SX để hình thành TSCĐ.
– Công trình trên đất mượn, thuê được trích khấu hao nếu: có hợp đồng công chứng, thời gian thuê không được thấp hơn thời gian khấu hao tối thiểu; có hóa đơn thanh toán công trình kèm hợp đồng xây dựng và thanh lý quyết toán hợp đồng; được hạch toán.
– Phần trích khấu hao TSCĐ vượt quá giá trị qui định (1,6 tỉ) đ/v tài sản là xe ô tô chở người từ 9 chỗ trở xuống không được tính vào chi phí. Tàu bay dân dụng, du thuyền không dùng cho kinh doanh vận chuyển.
– Chi quảng cáo, tiếp thị, khuyến mại… 10%. Riêng DN mới thành lập 3 năm đầu là 15% (không áp dụng đ/v hợp nhất, chia, tách, sáp nhập, chuyển đổi hình thức, sở hữu.
– Chi trả lãi tiền vay ngoài (không thuộc các ngân hàng và tổ chức tín dụng): giới hạn trong 1,5 lần lãi suất cơ bản tại thời điểm vay (trước đây là 1,2 lần lãi suất cho vay cao nhất của tổ chức tín dụng DN có quan hệ giao dịch).
– Chi nguyên vật liệu, nhiên liệu, năng lượng, hàng hóa phần vượt mức tiêu hao hợp lý. DN tự xây dựng định mức tiêu hao và thông báo với cơ quan thuế trong vòng 3 tháng kể từ khi SX theo mức tiêu hao được xây dựng. Trường hợp có điều chỉnh bổ sung phải thông báo chậm nhất lúc nộp quyết toán.
– Hàng hóa, dịch vụ mua vào không có hóa đơn được lập bảng kê nhưng không lập bảng kê kèm theo chứng từ thanh toán.
– Chi phí tiền lương phải trả nhưng hết thời hạn nộp quyết toán năm thực tế chưa chi trừ DN có lập quĩ dự phòng để bổ sung vào quĩ tiền lương của năm sau nhằm bảo đảm việc trả lương không bị gián đoạn, mức dự phòng không quá 17% quĩ lương thực hiện.
– Tiền lương của chủ DNTN, Cty TNHH 1 thành viên, thù lao cho sáng lập viên, thành viên không điều hành.
– Chi phí tiền ăn giữa ca theo thực tế (bỏ khống chế theo lương tối thiểu)
– Bỏ: Chi tiền ăn định lượng trong ngành đặc biệt vượt mức chế độ Nhà nước qui định
– Chi trang phục bằng hiện vật quá 1-500.000 đ/người/năm; chi bằng tiền vượt quá 1.000.000 đ/người/năm.
– Bỏ mức khống chế 1,5 tháng lương tối thiểu đ/v chi bồi dưỡng lao động nữ sau khi sinh con lần một, lần hai.
– Bổ sung: chi tài trợ cho cơ sở y tế, chi tài trợ khắc phục hậu quả thiên tai, chi tài trợ làm nhà tình nghĩa cho người nghèo được đưa vào chi phí.
– Bổ sung: giá trị tổn thất do thiên tai, dịch bệnh và trường hợp bất khả kháng khác không được bồi thường được đưa vào chi phí.

III. Trích lập quĩ phát triển khoa học và công nghệ
• DN được trích tối đa 10% thu nhập tính thuế hàng năm trước khi tính thuế TNDN để lập quĩ phát triển KH-CN.
• Hàng năm DN phải lập báo cáo trích, sử dụng quĩ phát triển KH-CN vào tờ khai quyết toán thuế TNDN.
• Trong thời hạn 5 năm, kể từ khi trích lập Quĩ mà không sử dụng hoặc sử dụng không hết 70% hoặc sử dụng không đúng mục đích thì phải nộp phần thuế TNDN và phần lãi phát sinh.
• Lãi suất tính lãi là lãi suất trái phiếu kho bạc loại kỳ hạn một năm và thời gian tính lãi là hai năm.

IV. Thuế suất thuế TNDN
– Thuế suất phổ thông: 25% (thay cho 28%)
– Thuế suất đặc biệt: 32%-50%
– Thuế suất ưu đãi: 10%; 20% (có điều kiện và thời gian hạn chế).
Bãi bỏ thuế bổ sung đ/v thu nhập từ chuyển nhượng bất động sản.

V. Nơi nộp thuế
-Nộp thuế nơi đóng trụ sở chính
-Nộp thuế nơi có CSSX, CSSX hạch toán phụ thuộc.
Số thuế TNDN nơi CSSX hạch toán phụ thuộc = Thuế TNDN phải nộp trong kỳ (x) Tỉ lệ CP của CSSX hạch toán phụ thuộc
Tổng CP của CSSX hạch toán phụ thuộc
Tỉ lệ CP của CSSX hạch toán phụ thuộc =
Tổng chi phí của doanh nghiệp
•Quyết toán thuế
Quyết toán thuế tại nơi có trụ sở chính
Số thuế còn phải nộp hoặc hoàn khi quyết toán cũng được phân bổ theo tỉ lệ.
Chi phí hoa hồng môi giới tại nước ngoài
Công văn số 137/ TCT-CS ngày 13/1/2009 của Tổng cục Thuế hướng dẫn về chi phí hoa hồng môi giới tại nước ngoài như sau:
Các khoản chi hoa hồng môi giới tiêu thụ sản phẩm ở nước ngoài được xem là chi phí hợp lý để tính thuế TNDN khi có đủ các điều kiện sau:
-DN có Qui chế hoa hồng môi giới áp dụng thống nhất trong DN. Mức chi hoa hồng môi giới phù hợp với mức khống chế về chi phí quảng cáo, tiếp thị, khuyến mại…
-Khoản chi hoa hồng môi giới phải thể hiện trong hợp đồng và phụ kiện, phụ lục, và có chứng từ hợp pháp chứng minh.
-Trường hợp người hưởng hoa hồng không thể ký vào phiếu chi hoặc không đồng ý thể hiện trong hợp đồng, phụ kiện, phụ lục thì chứng từ chi phải có chữ ký của giám đốc, kế toán trưởng, thủ quĩ. Người nhận tiền phải ký tên (ghi rõ họ tên, địa chỉ) vào giấy nhận tiền.

 

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