| Capital is the "bloodline" of enterprise operation.For an established group enterprise,it is particularly important to allocate resources to the new business sector accurately and effectively,and to coordinate with the group to adjust the direction of operation with the purpose of achieving transformation and upgrading in response to changes in the market.However,due to the fact that banks and other financial institutions are in the dilemma of guaranteeing the security of funds and asymmetric information on risk assessment of loan enterprises,these institutes tend to have a higher threshold for new business types and new business ecology.After all,the enterprises that can benefit from the "blood transfusion treatment” of loan from financial institutions are limited.More and more domestic enterprise groups refer to an alternative way of developing an internal capital market by foreign multinational groups,as a result,more and more attention has been paid to improving the efficiency of internal capital utilization.Among them,the "capital pool" mode is one of the most widely used internal capital market application modes for domestic groups.However,nationwide,the number of groups using the "fund pool" model is limited,the group itself has limited knowledge of the tax-related risks of the "fund pool" model,and there is a lack of formality in current tax policies.Many group enterprises have buried tax risks when using the"fund pool" model.Therefore,a tax-related risk analysis with regards to the “fund pool” is crucial implications for our current practice.Group A Limited Liability Company is a construction material manufacturing enterprise with a large scale in the province.In order to obtain raw materials effectively and with a limited market radius,it has branches all over the country at the early stage of enterprise development.At the same time,with the consideration that the market demand for building materials is gradually stabilized,Group A is making great efforts to transform,upgrade and expand the new business sector,starting in 2017.The company started to implement the "fund pool" model in the group in 2018 to tap the potential of the internal capital market.Restricted by factors such as the short time of using the "fund pool" model,the lack of understanding of the business model,the insufficient attention paid by the group headquarters to the tax-related risks of internal transactions,the high evaluation of tax compliance and the neglect of updating the internal control system,etc.,in the tax year after the implementation of the "fund pool" model,the group headquarters and departments branches were given tax-related risk suggestions by the competent tax authorities,which had a certain negative impact on the evaluation of tax credit rating in that year.The author belives that taking Group A as an example has far-reaching significance to analyze the trend of "fund pool" mode in the domestic promotion and to refine the tax-related risks that may occur after promotion for improving the construction of "fund pool" mode.Following the idea of finding existing problems,analyzing the causes of the problems and providing solutions,this paper analyzes and studies the main tax-related risks such as less revenue recognition of the group as a whole and more financial expenses of subsidiaries within the group when using the "capital pool" mode from the perspective of enterprises.By combining theoretical analysis with investigation and research,through interviews with tax executives at group headquarters and representative enterprises,this paper deeply understands the current tax compliance of Group A Limited Liability Company,identifies the existing problems,deeply analyses the causes of the problems,and then puts forward the prevention and control of the use of funds.The feasible countermeasures of tax risk of "pool model” are expected to help promote the promotion of "pool of funds" model and provide reference for more enterprises to use the "pool of funds" model. |
