Research On Tax Policy Of Special Purpose Vehicles In Asset Securitization In China

Asset securitization is the most important financial innovation in the international financial market in the second half of the 20 th century.Unlike traditional financing instruments,asset securitization creatively adds the role of special purpose vehicles in its operational processes.Special purpose vehicles rely on their risk isolation capabilities to help companies that have low credit but have good assets to raise funds quickly.Therefore,asset securitization has received more and more attention in China's current financial market.In recent years,the number of products issued in China's asset securitization market has been steadily increasing.In 2018,the annual issuance scale exceeded 2 trillion yuan,and the stock at the end of the year reached more than 3 trillion yuan.Compared with the significant growth in 2017,many “first-order” innovative products have been successfully issued,playing an important role in revitalizing existing assets,defusing adverse risks,and helping inclusive finance.While the asset securitization market is developing steadily,we should also note that there are still some unfavorable factors that hinder the further development of asset securitization.Transaction costs are an unavoidable topic for any financing instrument.When the sponsor considers which financing tool to choose,the cost comparison plays a decisive role.Because taxes are mandatory,tax costs naturally become the main target of planning.Compared with direct loan financing,asset securitization involves more trading entities,and each subject may face tax problems.The tax burden of each subject will directly or indirectly affect the investor's income,and it can also be said that the transaction is determined.Whether it can be successful.The special purpose vehicles is one of the main participants in asset securitization.Compared with the more perfect special purpose vehicles system in the United States,there are some legal disputes in the establishment of China's special purpose vehicles,which leads to the unclear status of its legal subject and lack of taxation.in accordance with.On the one hand,the tax staff has increased the difficulty of the work and affected the tax efficiency.On the other hand,the participation in the asset securitization has caused great uncertainty and brought operational risks to the financing process.The taxation cost affects the choice of the organization of the special purpose vehicles,which in turn affects the transaction structure of asset securitization,so it is necessary to study its tax treatment.This paper uses the case study method to explore the tax treatment of special purpose carriers in the securitization of property fee credit assets,and on this basis,the idea of experimenting with the tax treatment of special purpose companies.Through horizontal comparison,it is found that the tax burden of special purpose companies is not necessarily greater than the contractual special purpose carrier,because it can fully offset the VAT input tax.Further analysis shows that the current tax treatment of special purpose carriers has the following problems: lack of tax law basis,unclear tax status of corporate income tax,unclear definition of VAT taxpayers in the basic asset income link,and break of the VAT deduction chain.In this regard,this paper puts forward the following suggestions: improve the taxation regulations for asset securitization,relax the restrictions on special-purpose companies in law,unify the preferential channels for different forms of special-purpose carriers,grant special-purpose carrier income tax exemption subject status,and give special purposes.Carrier VAT taxpayer status,strengthen the tax collection and management of special purpose carriers.