Research On The Value-added Tax Treatment Of PPP Assets Securitization After The Reform Of The Business Reform

Asset securitization can improve the liquidity of PPP projects,speed up the withdrawal of funds,and attract social capital.Taxation is an important part of the cost of asset securitization.The correctness of taxation will inevitably affect the enthusiasm of all participating parties.However,the formulation and specification of relevant tax policies in China still remain in the early stage of the pilot of asset securitization business in China.2006 No.5 document still has many applicable obstacles to the asset securitization of PPP projects under the reform of the environment.In this paper,we will read and comprehend the value-added tax treatment policy of PPP asset securitization that has already been issued in China,and analyze the value-added tax treatment problems existing in the various aspects of asset securitization in combination with the commonly-represented future income asset securitization.The specific issues are:In the establishment of the special project for asset support,the unclear provisions for the real sales of basic assets may lead to the tax authority's levy of value-added tax on the transfer of basic assets for future income rights;in the operation of the asset support plan,the current regulations may make the management People can't issue invoices to themselves and thus lead to the breakage of the VAT offset chain.Provisions for 'guaranteed income' may provide planning space and distort the development of PPP asset securitization;Whether the income generated by the basic assets is subject to VAT may lead to repeated tax payments by investors and increase the tax burden.Finally,from the two aspects of transaction link and invoice management,the following suggestions are made:establish a real sales standard in the establishment of the asset support plan;impose a VAT on the income generated by the asset management product in the operation of the asset support plan;The link exempts the investor's income from the value-added tax;for the invoice management,the main body of the invoice is clearly defined on the basis of determining the taxation relationship.