to issue 97 ordinary VAT invoices that are inconsistent with the actual business conditions, with a total price and tax of 32301409.80 yuan, which are used to disburse costs.
as expenditure vouchers without real goods transactions.
28 of the State Administration of Taxation in 2018) According to the provisions of Article 12, the above expenses shall not be deducted before corporate income tax.
1 illegal act type: illegal facts of invoice: (I) your company has the illegal fact that you let others issue ordinary VAT invoices for yourself that are inconsistent with the actual business conditions in 2018, which is used to disburse costs, resulting in less payment of enterprise income tax.
Your company did not raise any objection to this illegal fact, but put forward the statement of “approved collection” on the collection method of supplementary tax.
After verification, in 2018, your company asked Wuchuan Dongtai building materials Co., Ltd.
Without labor costs, “materials” account for 91.76% of the “main business income” and 99.11% of the “main business cost”, which is inconsistent with the composition of production and operation costs of construction and decoration projects, And the vast majority of the “materials” listed are false invoices issued by Wuchuan Dongtai building materials Co., Ltd.
According to item (4) of paragraph 1 of Article 35 of the law of the people’s Republic of China on the administration of tax collection, item (2) of paragraph 1 of Article 47 of the detailed rules for the implementation of the law of the people’s Republic of China on the administration of tax collection, paragraph 1 of Article 4 and Article 8 of the enterprise income tax law of the people’s Republic of China Item (4), paragraph 1, Article 3 of the measures for the verification and collection of enterprise income tax (Guo Shui Fa [2008] No.
to issue an ordinary VAT invoice for itself that is inconsistent with the actual business situation, with a total amount of 54968.00 yuan for expenses.
The specific adjustments are as follows: your company self declared taxable income of 1214772.73 yuan in 2019, increased taxable income of 54968.00 yuan in this inspection and adjustment, and made up for the loss of 14245.00 yuan in 2017, The taxable income after making up the losses of previous years is 1255495.73 yuan (1214772.73 + 54968.00-14245.00), and the taxable amount is 313873.93 yuan (1255495.73 × 25%), the paid tax is 303693.18 yuan, and your company paid 10180.75 yuan less corporate income tax in 2019 (313873.93-303693.18)..
Name of administrative counterpart: Zhanjiang * * * Decoration Engineering Co., Ltd.
and Wuchuan Xiangtai building materials Co., Ltd.
and Wuchuan Xiangtai building materials Co., Ltd.
The taxable income of your company is 35518639.01 yuan as the taxable income of corporate income tax.
1), Our bureau has decided to levy the corporate income tax of your company in 2018 by means of verification.
administrative punishment decision document No.: Zhanshui Sanji Punishment [2022] No.
The cost accounting of your company in 2018 is not true.
30), and Article 1 of the announcement of the State Administration of Taxation of Guangdong Province and the Local Taxation Bureau of Guangdong Province on adjusting the taxable income rate of enterprise income tax (announcement of the State Administration of Taxation of Guangdong Province and the Local Taxation Bureau of Guangdong Province [2018] No.
Your company can only provide the project contract, partial material requisition and project progress confirmation data, and our bureau cannot verify the real cost.
Our bureau issued a notice on tax matters to your company, instructing your company to provide legal and valid invoices, payment vouchers, material acceptance and warehousing vouchers, material receiving and outbound vouchers for materials purchased for engineering projects in 2018, as well as the number, name, identity information, entry time, attendance records, wage verification and salary payment vouchers of workers, But your company failed to provide.
The taxable income rate of your construction industry is 8%, the corporate income tax rate is 25%, and the taxable income and taxable amount are verified as follows: your company’s declared operating income of 35518639.01 yuan in 2018, The approved taxable income is 2841491.12 yuan (35518639.01 yuan) × 8%), and the income tax payable is 710372.78 yuan (2841491.12 yuan) × 25%), the tax paid is 94034.50 yuan, and your company paid 616338.28 yuan less corporate income tax in 2018 (710372.78-94034.50).
The “main business cost” disbursed in the book is 32884729.06 yuan, mainly 32593495.97 yuan of “materials”.
(II) in 2019, your company had the illegal fact that you let others issue ordinary VAT invoices for yourself that are inconsistent with the actual business conditions for expenses, resulting in less payment of enterprise income tax.
587 of the State Council of the people’s Republic of China), item 2 of paragraph 2 of Article 22, article 4 of the measures for the administration of pre tax deduction vouchers of enterprise income tax (Announcement No.
In 2019, your company asked Shenzhen * * * Property Management Service Co., Ltd.
Our bureau believes that although your company has set up account books, the cost data and expense vouchers are incomplete.
According to Article 19, paragraph 2 of Article 21 of the law of the people’s Republic of China on the administration of tax collection, paragraph 1 of Article 29 of the detailed rules for the implementation of the law of the people’s Republic of China on the administration of tax collection, paragraph 1 of Article 1, paragraph 2 of Article 2, paragraph 1 of Article 4, Article 5 and Article 8 of the enterprise income tax law of the people’s Republic of China Article 27 of the regulations for the implementation of the enterprise income law of the people’s Republic of China, Article 21 of the measures for the administration of invoices of the people’s Republic of China (Order No.