tax on enterprise profits oor Sjinees

tax on enterprise profits

Vertalings in die woordeboek Engels - Sjinees

利得税

利润税

voorbeelde

The Profits Tax will also assist private economic development by allowing enterprises that operate acceptable accounting systems to move from the presumptive tax on turnover to a tax on profits after operating costs
利润税也有助于私营经济的发展,因为这种税收使得企业能够实行可接受的会计制度,从依据营业额的推定税额办法改成一种对扣除运营费用后的利润征税的办法。

[W]hen an enterprise of a Contracting State carries on business in the other Contracting State the authorities of that second State have to ask themselves two questions before they levy tax on the profits of the enterprise: the first question is whether the enterprise has a permanent establishment in their country; if the answer is in the affirmative the second question is what, if any, are the profits on which that permanent establishment should pay tax.
一缔约国企业在另一缔约国开展业务时,第二国当局在对该企业利润征税前须向自己提出两个问题:第一个问题是该企业在它们国家是否有常设单位;如果答复有,第二个问题是哪些利润(如有)属常设单位应纳税的利润。

In the words of the OECD Commentary, “The re-writing of transactions between associated enterprises in the situation envisaged in paragraph 1 may give rise to economic double taxation (taxation of the same income in the hands of different persons), insofar as an enterprise of State A whose profits are revised upwards will be liable to tax on an amount of profit which has already been taxed in the hands of its associated enterprise in State B.”
用经合组织评注的话说,“重新编写联营企业之间在第1款设想的情况下进行交易的内容可能导致经济上的双重征税(对不同的人持有的同一笔收入的征税),因为利润上调的A国企业有责任就其在B国的联营企业手中已被征税的一些利润纳税”。

In the words of the OECD Commentary, “The rewriting of transactions between associated enterprises in the situation envisaged in paragraph 1 may give rise to economic double taxation (taxation of the same income in the hands of different persons), in so far as an enterprise of State A whose profits are revised upwards will be liable to tax on an amount of profit which has already been taxed in the hands of its associated enterprise in State B.”
用经合发组织评注的话说,“重新编写联营企业之间在第1款设想的情况下进行交易的内容可能导致经济上的双重征税(不同人的手中同笔收入的征税),因为其利润上调的A国企业有责任对其在B国的联营企业手中已被征税的一些利润纳税”。

Meanwhile, they will be free to use part of their fortune as impact investors in for-profit social enterprises that promise both financial and social returns (and they will have to pay taxes on the profits they reap).
与此同时,他们也可以用部分财富作为影响力投资者投资营利性社会企业,获得财务和社会回报(他们必须为所获利润缴税)。

However, where the place of effective management of the enterprise is situated in the other State and that other State imposes tax on the whole of the profits of the enterprise from the operation of ships or aircraft, the profits from the operation of ships or aircraft, other than those from transport by ships or aircraft operated solely between places in the first-mentioned State, may be taxed in that other State.
不过,如果企业的有效管理地位于另一国,而且该另一国对企业经营船舶或飞机的全部利润征税,则经营船舶或飞机的利润,除船舶或飞机都在首次提及国两地之间从事运输所得的利润外,可在该另一国纳税。

However, where the place of effective management of the enterprise is situated in the other State and that other State imposes tax on the whole of the profits of the enterprise from the operation of ships or aircraft, the profits from the operation of ships or aircraft, other than those from transport by ships or aircraft operated solely between places in the first-mentioned State, may be taxed in that other State.’ ” [para.
不过,如果企业的有效管理地位于另一国,而且该另一国对企业经营船舶或飞机的全部利润征税,则经营船舶或飞机的利润,除船舶或飞机都在首次提及国两地之间从事运输所得的利润外,可在该另一国纳税。’”[

· Tax credit for research: Any enterprise liable to the profits tax which engages in expenditure on research and development may obtain a tax credit amounting to 50 per cent of the difference between the research expenditure during the year and the average expenditure during the two preceding years, subject to a ceiling on the total allowable expenditure.
· 科研税收抵免:有缴纳利得税义务但有研发支出的任何公司,可以获得相当于当年科研支出额与前两年平均支出差额50%的税收抵免,视允许支出总额的上限而定。

Structure and rate of tax In countries where enterprises, mainly companies, are charged a tax on their profits which is specific to them, the provisions of paragraph # raise, with regard to the rate applicable in the case of permanent establishments, especially difficult and delicate problems, which here too arise from the fact that the permanent establishment is only a part of a legal entity which is not under the jurisdiction of the State where the permanent establishment is situated.” [para
“在按具体情况对企业,主要是对公司利润进行征税的国家,第 # 款的规定在适用于常设单位的税率上引起了特别棘手而微妙的问题,此外,这些问题的产生还与下列事实有关,即常设单位只是法律实体的一部分,不属于常设单位所在国的管辖范围。”

Where a performance takes place in such a country, paragraph # permits it to impose a tax on the profits diverted from the income of the artiste or sportsman to the enterprise
如果演出在此类国家进行,按第 # 款规定,它可以对从演艺人员或运动员的收入中拨给企业的利润征税。

Some States, for example, would prefer the system under which, where the profits of enterprise X in State A are increased to what they would have been on an arm’s length basis, the adjustment would be made by reopening the assessment on the associated enterprise Y in State B containing the doubly taxed profits in order to reduce the taxable profit by an appropriate amount.
例如,有些国家较赞成采用以下方法,即如果A国X企业的利润增至在公平基础上所能达到的水平,则要对B国Y企业包括双重征税利润在内的利润重新进行税款估定,并据此作出调整,以便从应纳税利润中扣除一定的数额。

But it is thought that it is preferable to adopt the principle contained in the second sentence of paragraph 1, namely that the test that business profits should not be taxed unless there is a permanent establishment is one that should properly be applied not to the enterprise itself but to its profits.
但是人们认为,最好采用第1款第2句所阐明的原则,即只有存在一个常设单位,才可对营业利润进行征税,这是一项检验标准,将它适用于企业本身而不是企业的利润才对。

Activities include, among others, employment in tourism enterprises; supply of goods and services to tourism enterprises; direct sales of goods and services to visitors; and tax or levy on tourism or profits with proceeds benefiting them
这些活动包括旅游企业提供就业;向旅游企业提供商品和服务;直接向游客出售商品和服务;旅游业收取税赋。

“The second and more important point [stated in the second sentence] is that . . . when an enterprise carries on business through a permanent establishment in another State that State may tax the profits of the enterprise but only so much of them as is attributable to the permanent establishment; in other words that the right to tax does not extend to profits that the enterprise may derive from that State otherwise than through the permanent establishment.
“第二点,也是更重要的一点[在第二句中说明]是......当一个企业通过在另一国的常设单位开展业务活动时,该另一国可以对企业的利润征税,但只限于可归属该常设单位的部分;换句话说,征税权的范围并不扩大到企业通过非常设单位途径从该国可能取得的利润。

“While this approach does not create any problems with regard to the provisions of paragraph # of Article # in the case of countries where a withholding tax is levied on all such income, whether the latter be paid to residents (permanent establishments, like resident enterprises, being allowed to set such withholding tax off against the tax on profits due by virtue of Article # ) or to non-residents (subject to the limitations provided for in Articles # and # ), the position is different when withholding tax is applied exclusively to income paid to non-residents.” [para
“在一些国家对所有此类收入--不论是支付给居民的收入(常设单位同居民企业一样,可以使用按第 # 条应支付的利润税抵消预扣税)还是支付给非居民的收入(需遵守第 # 、 # 和 # 条规定的限制)--征收预扣税的情况下,仍可适用第 # 条第 # 款的规定,但预扣税只适用于支付给非居民的收入时,情况就不同了。”

“While this approach does not create any problems with regard to the provisions of paragraph 3 of Article 24 in the case of countries where a withholding tax is levied on all such income, whether the latter be paid to residents (permanent establishments, like resident enterprises, being allowed to set such withholding tax off against the tax on profits due by virtue of Article 7) or to non-residents (subject to the limitations provided for in Articles 10, 11 and 12), the position is different when withholding tax is applied exclusively to income paid to non-residents.” [para.
“在一些国家对所有此类收入——不论是支付给居民的收入(常设单位同居民企业一样,可以使用按第7条应支付的利润税抵消预扣税)还是支付给非居民的收入(需遵守第10、11和12条规定的限制)——征收预扣税的情况下,仍可适用第24条第3款的规定,但预扣税只适用于支付给非居民的收入时,情况就不同了。”[

Notes the work of the subcommittees on substantial matters, namely article 9 (associated enterprises): transfer pricing; tax treatment of services; exchange of information; base erosion and profit-shifting issues for developing countries; extractive industries taxation issues for developing countries; and negotiation of tax treaties — practical manual, as well as an advisory group on capacity development;
注意到各实务问题小组委员会的工作,即第9条(联属企业):转让定价;服务税务处理;信息交流;发展中国家税基侵蚀和利润转移问题;发展中国家采掘业征税问题以及税务条约谈判——实用手册;以及能力发展咨询小组;

To put the matter another way, the principle laid down in the second sentence of paragraph 1 is based on the view that in taxing the profits that a foreign enterprise derives from a particular country, the fiscal authorities of that country should look at the separate sources of profit that the enterprise derives from their country and should apply to each the permanent establishment test.
换言之,第1款第二句规定的原则基于这样一种意见,即在对一个外国企业从特定国家获得的利润进行征税时,该国财政当局应当查明该企业从它们国家获得利润的不同来源,并应将常设单位检验标准适用于每种来源。

The business profits of an enterprise of a Contracting State are exigible to tax in that State alone unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.
一缔约国企业的营业利润只应在该国纳税,除非该企业通过建在另一缔约国的常设单位在该国经营业务。

Notes the decision of the Committee, at its ninth session, to set up six subcommittees on substantial matters, namely article 9 (associated enterprises): transfer pricing; tax treatment of services; exchange of information; base erosion and profit-shifting issues for developing countries; extractive industries taxation issues for developing countries; and negotiation of tax treaties — practical manual, as well as an advisory group on capacity development;
注意到委员会第九届会议决定设立六个实务方面的小组委员会,即第9条(联合企业):转让定价;服务的税务处理;信息交流;发展中国家税基侵蚀和利润转移问题;发展中国家采掘业征税问题;税务条约谈判——实用手册;以及设立一个能力发展咨询小组;

Notes the decision of the Committee, at its ninth session, to set up six subcommittees on substantial matters, namely article 9 (associated enterprises): transfer pricing; tax treatment of services; exchange of information; base erosion and profit-shifting issues for developing countries; extractive industries taxation issues for developing countries; and negotiation of tax treaties — practical manual, as well as an advisory group on capacity development;
注意到委员会第九届会议决定设立六个小组委员会审议实务问题,即第9条(联合企业):转让定价;服务税务处理;信息交流;发展中国家税基侵蚀和利润转移问题;发展中国家采掘业征税问题以及税务条约谈判——实用手册;并设立一个能力发展咨询小组;

Notes the decision of the Committee, at its ninth session, to set up six subcommittees on substantial matters, namely article 9 (associated enterprises): transfer pricing; tax treatment of services; exchange of information; base erosion and profit-shifting issues for developing countries; extractive industries taxation issues for developing countries; and negotiation of tax treaties — practical manual, as well as an advisory group on capacity development;
注意到委员会第九届会议决定设立六个小组委员会审议实务问题,即第9条(联属企业):转让定价;服务税务处理;信息交流;发展中国家税基侵蚀和利润转移问题;发展中国家采掘业征税问题以及税务条约谈判——实用手册;并决定设立一个能力发展咨询小组;

The article provides that the profits of an enterprise shall be taxed only in the State where the enterprise is resident, unless it carries on business in the other contracting State (the source State) through a permanent establishment.
该条规定,应只在企业所在国对企业利润征税,除非企业通过一个常设单位在另一缔约国(来源国)开展业务。

The States in favour of extending the split-rate system to permanent establishments urge that as the essential feature of this system is a special technique of taxing profits which enterprises in a corporate form derive from their activities, and is designed to afford immediate relief from the double taxation levied on the profits distributed, it should be applied to permanent establishments in bilateral conventions against double taxation
赞成将分割税率制扩大到常设单位的国家认为,这种税制的基本特点是采取一种特殊方法,对公司企业开展活动所得的利润进行征税,并迅速减免对已分配利润的双重征税,因此它们敦促在防止双重征税的双边公约范围内对常设单位适用这一制度。