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

ovable property”； if the method of paying fixed profits to the Chinese party is adopted， then business tax is levied on all the incomes gained by the foreign party from the sales of commodity houses in accordance with the stipulation of “selling immovable property”。

　　II. The taxation question concerning the development expenses gained from the first-phase project by the Chinese party

　　The development expenses for the first-phase project paid in advance by the foreign party to the Chinese party shall be regarded as the business income gained by the Chinese party by the method of receiving the money in advance， business tax is calculated and levied in line with the stipulation of the transfer of land-use right. With regard to this already taxed development expense， which shall be accurately deducted from the due income of the Chinese party， may directly eat up the current business income of the Chinese party.

　　III. The fixed profits gained regularly by the Chinese party sh

all be regarded as the income gained by the transfer of the land-use right， on which business tax is calculated and levied

上一页  [1] [2] [3]