Research On The Value-added Tax System Of Asset Securitization In China

Asset securitization originated in the United States in the 1960 s and plays an important role in invigorating assets and enhancing asset liquidity in the American capital market.Since 2004,asset securitization,a financial innovation means,has been introduced into China and gradually played an important role in China's capital market.Asset securitization,which was initially introduced to serve the non-performing assets of Banks,has gradually evolved and expanded in China's capital market and extended to various fields,becoming an important financing channel for various economic entities in China.The key to whether asset securitization can play its role in broadening financing channels and optimizing resource allocation in the current environment lies in the transaction cost,which depends on the tax burden.With the arrival of the comprehensive "replacement of business tax with value-added tax" era in China on May 1,2016,the policy basis of no.5 document [2006],which was originally applicable to the asset securitization business,became invalid,replaced by a series of new policies of "replacement of business tax with value-added tax"."Replacing the business tax with a value-added tax" means replacing the original business tax with a value-added tax in order to reduce the tax burden,further reduce the burden on enterprises and improve economic vitality.However,the introduction of the new policy of replacing business tax with value-added tax still has obstacles and problems in the application process of asset securitization business.This paper starts with the analysis of value-added tax factors related to transactions of different subjects of asset securitization,and combines with the securitization case of accounts receivable in the real estate field of pingan-vanke supply chain finance no.1,to propose solutions to the difficulties of value-added tax system faced by China's current enterprise asset securitization.The first part of this paper introduces the VAT tax-related elements of each transaction subject in each transaction link,and analyzes them from the aspects of VAT taxpayer,tax range,tax rate,collection method and tax items.The second part introduces the VAT systemdilemma faced by the application of the new policy.The third part introduces the principles of tax neutrality and tax substance that should be considered in the tax control design of asset securitization.The fourth part introduces the case of securities of accounts receivable and summarizes its problems.The fifth part puts forward countermeasures from the aspects of clarifying whether the transfer of basic assets should be included in the scope of VAT collection,clarifying the status of the special purpose carrier as the main taxpayer,improving the VAT collection scheme of asset securitization,and improving the design of VAT tax control by adhering to the principle of tax neutrality.