鲜花( 87) 鸡蛋( 1)
|
楼主 |
发表于 2011-3-10 20:46
|
显示全部楼层
至于Forex 是否属于增值, 税务局文档 IT-95R 提到
) D/ h/ g6 {, @- Z1 u8 L2 P7 k! g( w) B o# ~3 p: B
2. Where it can be determined that a gain or loss on foreign exchange arose as a direct consequence of the purchase or sale of goods abroad, or the rendering of services abroad, and such goods or services are used in the business operations of the taxpayer, such gain or loss is brought into income account. If, on the other hand, it can be determined that a gain or loss on foreign exchange arose as a direct consequence of the purchase or sale of capital assets, this gain or loss is either a capital gain or capital loss, as the case may be. Generally, the nature of a foreign exchange gain or loss is not affected by the length of time between the date the property is acquired (or disposed of) and the date upon which payment (or receipt) is effected.' X5 [: r( a% H* R5 A& D1 v$ `
3 b. J& i: C( C! X6 z& O3 y1 n
从以上条文不难看到, 税务局对Forex 增值或普通收入的解说是模棱两可的。关键是 Direct consequence of purchase/sales of capital assets. |
|