造成增值税与所得税申报收入不一致的原因

虽然企业所得税法及其实施条例定的“收入总额”包含的收入项目比较多,但2014版《〈中华人民共和国企业所得税年度纳税申报表(A类)〉填报说明》中规定:“‘利润总额计算’中的项目,按照国家统一会计制度口径计算填报。”这其中的“营业收入”包括“主营业务收入”、“其他业务收入”、“营业外收入”三部分(以下简称“三项收入”)。在企业所得税年度纳税申报表中,这“三项收入”是要求按照会计上国家统一的会计制度核算数据填报的。按照会计核算要求,有相当一部分按税法规定应当纳税的所得税收入是不在或不完全在“三项收入”中核算的,在年度所得税申报时,需分别通过《纳税调整项目明细表》及主表、其他附表的相关栏目对应纳税所得额进行调整。也就是说,增值税与企业所得税申报收入额的差异实际是增值税申报的收入额与会计核算收入额的差距,因此,其原因主要有以下三个方面:

一、确认收入的条件不同

增值税暂行条例及其实施细则和《企业会计准则》及其应用指南对各自的收入确认都有明确规定,但《企业会计准则》规范的主要是会计核算环节的会计行为,出于谨慎性和稳健原值,《企业会计准则第14号——收入》将销售商品、提供劳务、让渡资产等收入的确认都规定必须几个条件同时满足才能确认收入,即:

(一)确认销售商品收入必须同时满足五个条件:

1.企业已将商品所有权上的主要风险和报酬转移给购货方;

2.企业既没有保留通常与所有权相联系的继续管理权,也没有对已售出的商品实施有效控制;

3.收入的金额能够可靠地计量;

4.相关的经济利益很可能流入企业;

5.相关的已发生或将发生的成本能够可靠地计量。

(二)确认提供劳务交易必须同时满足四条件:

1.收入的金额能够可靠地计量;

2.相关的经济利益很可能流入企业;

3.交易的完工进度能够可靠地确定;

4.交易中已发生和将发生的成本能够可靠地计量。

(三)确认让渡资产使用权收入必须同时满足两个条件:

1.相关的经济利益很可能流入企业;

2.收入的金额能够可靠地计量。

增值税暂行条例及其实施细则规范的是企业纳税行为,涵盖产、供、销及内部管理各个环节,强化对企业纳税行为的规范和监督。税法规定只要有一种行为发生就确认为计税收入的实现,如《中华人民共和国增值税暂行条例》(国务院令第538号,以下简称《增值税暂行条例》)第十九条规定:销售货物或者应税劳务,为收讫销售款项或者取得索取销售款项凭据的当天;先开具发票的,为开具发票的当天;进口货物,为报关进口的当天。

《中华人民共和国增值税暂行条例实施细则》(财政部、国家税务总局令第50号,以下简称《实施细则》)第三十八条规定:条例第十九条第一款第(一)项规定的收讫销售款项或者取得索取销售款项凭据的当天,按销售结算方式的不同,具体为:

(一)采取直接收款方式销售货物,不论货物是否发出,均为收到销售款或者取得索取销售款凭据的当天;

(二)采取托收承付和委托银行收款方式销售货物,为发出货物并办妥托收手续的当天;

(三)采取赊销和分期收款方式销售货物,为书面合同约定的收款日期的当天,无书面合同的或者书面合同没有约定收款日期的,为货物发出的当天;

(四)采取预收货款方式销售货物,为货物发出的当天,但生产销售生产工期超过12个月的大型机械设备、船舶、飞机等货物,为收到预收款或者书面合同约定的收款日期的当天;

(五)委托其他纳税人代销货物,为收到代销单位的代销清单或者收到全部或者部分货款的当天。未收到代销清单及货款的,为发出代销货物满180天的当天;

(六)销售应税劳务,为提供劳务同时收讫销售款或者取得索取销售款的凭据的当天;

(七)纳税人发生《实施细则》第四条第(三)项至第(八)项所列视同销售货物行为,为货物移送的当天。

由于上述税收规定与会计的差异,造成增值税申报的“销售额”大于会计核算的收入额。

二、确认收入的范围不同

除在销售商品、提供劳务和让渡资产时确认增值税计税收入与确认会计核算收入的条件不一致外,两者确认收入的范围也不一致,增值税的计税收入除销售商品、提供劳务(包括提供增值税应税服务)、让渡资产的收入外,还包括以下在会计核算上不记入或者不完全记入“三项收入”的项目。

(一)视同销售收入

按照《实施细则》第四条的规定,单位或者个体工商户的下列行为,视同销售货物征收增值税:

1.将货物交付其他单位或者个人代销;

2.销售代销货物;

3.设有两个以上机构并实行统一核算的纳税人,将货物从一个机构移送其他机构用于销售,但相关机构设在同一县(市)的除外;

4.将自产或者委托加工的货物用于非增值税应税项目;

5.将自产、委托加工的货物用于集体福利或者个人消费;

6.将自产、委托加工或者购进的货物作为投资,提供给其他单位或者个体工商户;

7.将自产、委托加工或者购进的货物分配给股东或者投资者;

8.将自产、委托加工或者购进的货物无偿赠送其他单位或者个人。

这些在税收规定上视同销售计征增值税的收入,依照《企业会计准则》(以下简称《准则》)的规定,在会计上是不确定收入的,在发生时将成本和应缴纳的增值税直接记入相关成本(用于非增值税应税项目或投资等)、费用(用于集体福利、捐赠或转移其他机构和委托其他单位代销等)即可,但在增值税申报时必须在“销售额”中进行申报。

(二)价外费用

按照《增值税暂行条例》第六条及《实施细则》第十二条的规定,计征增值税的销售额为纳税人销售货物或者应税劳务向购买方收取的全部价款和价外费用,但是不包括收取的销项税额。其中“价外费用”包括在价外向购买方收取的手续费、补贴、基金、集资费、返还利润、奖励费、违约金、滞纳金、延期付款利息、赔偿金、代收款项、代垫款项、包装费、包装物租金、储备费、优质费、运输装卸费以及其他各种性质的价外收费。这些代收、代垫款项依照《准则》规定在应付、应收款中核算,不记入“三项收入”,但在增值税申报时要在“销售额”中进行申报。

不过,依照《实施细则》第十二条规定上述计征增值税的价外费用不包括受托加工应征消费税的消费品所代收代缴的消费税;代办保险等向购买方收取的保险费;代购买方缴纳的车辆购置税、车辆牌照费以及符合条件的代垫运输费用和代为收取的政府性基金或者行政事业性收费等。

(三)会计上不完全记入“三项收入”的处置非流动资产收入

依照《企业会计准则》和《企业会计准则应用指南——会计科目和主要账务处理》的规定,“营业外收入”科目核算企业发生的与其经营活动无直接关系的各项净收入,包括处置非流动资产利得、非货币性资产交换利得。即在处置固定资产、无形资产、生产性生物资产时,处置结果若为利得,将记入“营业外收入”科目的贷方,若为损失将损失记入“营业外支出”科目的借方;发生非货币性资产交换时(在非货币性资产交换非具有商业实质且公允价值能够可靠计量的情况下,包括固定资产、无形资产、存货),交换结果若为利得将利得分别记入“三项收入”相关科目的贷方,若为损失,将分别记入“主营业务成本”、“其他业务成本”、“营业外支出”科目的借方。但在增值税申报时要都要按全额申报纳税。

三、确认缴纳增值税的收入与会计核算的收入范围不同

在会计核算收入中,不征收增值税的收入包括两部分:一是债务重组利得、罚没利得、政府补助利得、确实无法支付而按规定程序经批准后转作营业外收入的应付款项等;二是所属建筑业、房地产开发、旅店、饭店、小额贷款公司等营业收入。前者既不属于征收增值税的项目,也不属于征收营业税的项目,后者属于不征收增值税的项目,但要按照税法规定要缴纳营业税。按照《企业会计准则》规定这两部分收入都应分别记入“三项收入”中。但在增值税申报时,申报的“销售额”是不包括这两部分收入的。

原创文章,转载请注明: 转载自飞月秀

本文链接地址: 造成增值税与所得税申报收入不一致的原因

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