In the complex international economic environment and fierce competition,many Chinese companies with the opportunity of merger and reorganization,successfully recover losses,even listed,enhance their industry competitiveness.Due to the growing reorganization market and the diversity of the types of corporate shareholders,the merger and reorganization of enterprises attracts more and more market players to participate,and natural person shareholders also play a more significant role in it.However,in the reorganization involving natural person shareholders,the relevant tax treatment still faces many problems.For example,there is no legal person shareholders can choose special or general tax treatment,and the unreasonable time point of revenue recognition and the performance compensation after the merger and reorganization have added a lot of problems to the natural person shareholders when participating in the merger and reorganization.If not attach importance to the problems and solve them,will eventually hinder the restructuring.Based on the analysis of the situation of the natural person shareholders in the Xingyuan Environmental acquisition case,this paper points out the problems faced by the natural person shareholders at the present stage: the incoordination of tax policies between the legal person shareholders and the natural person shareholders,the unreasonable time point of income recognition,the fuzzy treatment of personal income tax for performance compensation,the imperfect tax collection and management system and the unreasonable limited installment tax payment.Based on the theories of tax neutrality,tax sustainability and tax fairness,this paper puts forward corresponding suggestions from the perspectives of tax collectors and taxpayers.It is hoped that the future personal income tax related policies can be more perfect to reduce the bad guidance of tax policies to the market economy. |