Research On Taxation Policy Of PPP Asset Securitization In China

PPP asset securitization refers to the process in which the original equity holder(PPP project company)uses the PPP project as the underlying asset,issues the tradable securities in the capital market,and pays off the equity with the cash flow generated by its underlying assets.Asset securitization is a "double-edged sword" that has both positive effects in promoting economic development and negative effects on economic instability.The impact of tax cost and tax system design on asset securitization trading model is one of the key factors restricting the development of this new financing tool.The healthy development of PPP asset securitization requires a sound legal and regulatory environment.The current tax system fails to clearly define the property transfer standard of the original equity of the PPP asset securitization,the capital preservation and non-guarantee nature of the operating income of the asset support special plan,the nature of the investor's income and the taxation guidelines,etc.And then resulting in uncertain risks and constrain the enthusiasm of investors of PPP investment.The relevant tax regulations should be further improved,the tax environment should be optimized,and the development of PPP asset securitization should be promoted.This paper uses the literature research method,case analysis method and comparative analysis method to study the PPP asset securitization tax policy in China.The research content is divided into six parts: The first part is the introduction part.This part focuses on the background and research significance of PPP asset securitization taxation issues,and summarizes the research on PPP asset securitization and taxation issues at home and abroad,and the research ideas,research methods and innovations of this paper.The shortcomings are summarized,pointing out that the taxation issue is an important factor for the PPP asset securitization business to be properly handled;the second part is the introduction of PPP asset securitization and related taxation theory.This part mainly introduces PPP and China practice,asset securitization and China exploration,and then draws the current PPP development problem and the matching factors between PPP and asset securitization.It also introduces the tax analysis framework related to PPP asset securitization and basic taxation principles;the third part is case analysis.This chapter takes the CFLD(China Fortune Land Development)ABS project as an example.By introducing its product overview,transaction subject,transaction structure and product investment characteristics,it also proceeds from the basic asset transfer link,asset securitization project operation link and project income distribution link through the tax analysis framework described above to carry out tax-related analysis of this case;the fourth part analyzes the problems existing in China's PPP asset securitization tax policy.By introducing the existing tax policy of China's PPP asset securitization,based on the content discussed in the previous case analysis section,the specific problems of China's PPP asset securitization tax policy are obtained——the taxation object is not clear,the taxation link design affects the tax neutrality,the manager's tax status affects the efficiency of the collection and the taxable income limit is not clear.The fifth part is the experience of foreign asset securitization tax treatment.It introduces the tax treatment of different links in the United States,Britain,France and Japan,and then draws lessons from experience--clarifying tax laws and regulations and improving tax incentives.The sixth part is the policy suggestion part.From the basic asset transfer link,asset securitization project operation link and project income distribution link to propose relevant suggestions.