The Regulations on the Implementation of the Enterprise Income Tax Law stipulate: "The liquidation income refers to the balance of all the realizable value or transaction price of the enterprise's assets after deducting the net asset value, liquidation expenses and relevant taxes and fees." Ministry of Finance Notice of the State Administration of Taxation on Some Issues Concerning the Treatment of Enterprise Income Tax in Enterprise Liquidation Business2009:60(1) further clarified: "The liquidation income shall be the balance of all the realizable value or transaction price of the enterprise's assets, minus the tax basis of the assets, liquidation costs, relevant taxes and fees, plus the profit and loss of debt liquidation." As can be seen from the above provisions, liquidation income refers to the potential appreciation (or impairment) of all assets and liabilities of an enterprise at the time of closure and liquidation, which has not yet received income tax. It can also be understood as the taxable income (or loss) generated by assuming that an enterprise sells all assets and pays off all liabilities that must be repaid.
I. Differences between tax basis and accounting cost of assets
Notice of the State Administration of Taxation on Printing and Distributing the Income Tax Return for Enterprise Liquidation of the People's Republic of China (State Tax Letter [2009:388"Asset disposal profit and loss: refers to the amount of asset disposal income or loss recognized by the taxpayer after deducting the tax basis from the realizable value or transaction price of all assets." As can be seen from the above provisions, when calculating the asset disposal profit and loss, it is allowed to deduct the "tax basis" of the asset rather than the accounting cost. Therefore, when recognizing the liquidation income, the difference between the tax basis and the accounting cost of the taxpayer's assets should be fully reversed.
case1:AAt the time of liquidation, the book value of a fixed asset is120Ten thousand yuan, the taxable cost is200Ten thousand yuan, the realized value is220Ten thousand yuan. The reason for the difference between tax cost and accounting cost is that accounting provides for accelerated depreciation. The amount of depreciation previously deducted by the accounting is greater than the difference between the maximum amount of depreciation allowed by the tax law, and the taxable income has been adjusted to increase.
Variance analysis: When calculating liquidation income,AThe Company shall recognize the gain or loss from asset disposal as20Ten thousand yuan (220－200), and the accountant should recognize the gain on asset disposal100Ten thousand yuan (220－120), the difference between tax cost and accounting cost of fixed assets80Ten thousand yuan (200－120) on liquidation.
case2:2010years12The moon,BThe company purchased a production tool, the value100Ten thousand yuan, the expected service life is5The tax law stipulates that the depreciation life is not less than5Year) with an estimated net salvage value of5RMB ten thousand yuan, using the average life method of depreciation.2012At the end of the year, the company found the impairment of the equipment, and it is estimated that the recoverable amount is35In the amount of RMB 10,000 yuan, impairment reserves shall be accrued and withdrawn27Ten thousand yuan, the remaining service life is2Years, the salvage value remains the same.2015years7month1dayBThe company is closed for liquidation, the equipment is still in use, and the realized value is10Ten thousand yuan.BThe company makes the following accounting treatment:
①: Purchase equipment
Borrow: Fixed assets 1000000
Loan: bank deposit 1000000
②:2011Nian He2012Depreciation shall be deducted each year19Ten thousand yuan［(100-5)÷5］
Borrow: manufacturing expenses 190000
Credit: Accumulated depreciation 190000
③:2012Provision for impairment at year-end27Ten thousand yuan (100－19×2－35)
Borrow: asset impairment loss----Impairment loss on fixed assets 270000
Loan: reserve for impairment of fixed assets 270000
④:2013and2014Depreciation shall be deducted each year15Ten thousand yuan［(35－5)÷2］.
Borrow: manufacturing expenses 150000
Credit: Accumulated depreciation 150000
Difference analysis: The withdrawal of asset impairment reserve by taxpayers will lead to differences between the accounting cost and tax basis of assets, so it is not necessary to consider the tax adjustment of impairment reserve separately in the liquidation. In practice, because the accounting impairment reserve will affect the amount of depreciation and amortization, so the author believes that the asset impairment reserve should be treated as depreciation and amortization.2011Nian He2012The accountant takes depreciation every year19Ten thousand yuan, no difference with the tax law.BIn the company2012The reserve for impairment of fixed assets drawn at the end of the year shall not be deducted before tax and shall be declared to increase the taxable income27Ten thousand yuan, then the accounting cost of fixed assets is35Ten thousand yuan［100－(19×2)－27］, and the taxable cost is62Ten thousand yuan［100－(19×2)］.2013Year to year2014In a year,BAccording to the tax law, the company can withdraw depreciation every year before tax19Ten thousand yuan, whileBThe company's actual annual depreciation is15Therefore, the taxable income shall be declared to be adjusted or reduced annually4Ten thousand yuan (19－15),2015years1－6The depreciation actually extracted by the monthly accountant is0Therefore, the amount of taxable income shall be declared for adjustment or reduction9.5Ten thousand yuan (19÷2). So far, the accounting cost of this fixed asset is5Ten thousand yuan (estimated net salvage value), the tax basis is14.5Ten thousand yuan［62－(19×2)－9.5］. Losses from asset disposal shall be recognized when calculating the liquidation income4.5Ten thousand yuan (10－14.5), and the accountant should recognize the gain on asset disposal5Ten thousand yuan (10－5), all temporary differences arising from the provision for impairment of the asset will be reversed.
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