国家税务总局关于中外合作开发房地产征收营业税问题的批复 Official Reply on the Question Concerning the Levy of Business Tax on Chinese-foreign Cooperative Development of Real Estate

国家税务总局关于中外合作开发房地产征收营业税问题的批复 Official Reply on the Question Concerning the Levy of Business Tax on Chinese-foreign Cooperative Development of Real Estate

国税函发[1994]644号
颁布日期：19941206 　实施日期：19941206 　颁布单位：国家税务总局

　　GuoShuiHanFa [1994] No.644

　　December 6， 1994

　　The State Tax Bureau of Guangdong：

　　We have recently acknowledged the receipt of a letter from the Guangzhou Municipal Tax Bureau asking for Instructions on the Question Concerning the Levy of Business Tax on Cooperative Development of the Real Estate Sector， a document coded Shui Yi [1994] No. 327. The letter says that some domestic enterprises have cooperated with foreign businessmen in building commodity houses on the land where the supply of water， electricity and gas has been made available and the ground has been leveled， both parties set up cooperative companies and received business license， with the Chinese party transferring the land-use right to the cooperative companies， while the foreign party being responsible for all funds needed for the building of commodity houses and for the sales of commodity houses abroad， both sides adopted the distribution methods of distributing construction area and sales income and drawing fixed profits. The letter demanded that the question as to how to calculate and levy business tax related to the behavior of the transfer of land-use right involved in the above-mentioned business activities. After study， we now give the written reply as follows：

　　I. The taxati

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