Customer service refers to the leaseback by the plant owner will be part of their original possessions to the lessor to obtain financing, and then to cover the cost of rent, to lease back the way a lease transaction has sold property. When the enterprise appears the crisis of capital circulation, through the sale of assets to buy back, not only can make an inventory of assets, and even can be obtained operating income. The type of financing customer service leaseback concept embodied in: need not delay the production, at the same time to meet the capital turnover time form of payment to the enterprise space to use value for money, better alleviate the enterprises face in the expansion of the scale and technology update financial pressure. When the lease expires, the lessee will take a small amount of the ownership of the equipment to retrieve. Customer service leaseback is one kind of financing way of common international, it sets the financing and sales as a whole, is a new method of financing. Prior to the domestic use of the main ship and airline companies, but in recent years in many other industries have begun to adopt, especially in the mechanical equipment industry has been rapid development.
First, the advantages of customer service leaseback financing
Through customer service leaseback, enterprises will be transformed into fixed assets, current assets, without any increase in liabilities on the basis of improving the assets structure of enterprises, improve the financial situation. In some cases, the lessee can also through the customer service to those who can appreciate the leaseback of equipment, equipment of premium cash income. This is a lower threshold, less risk, a significant income financing.
At present, the main channel of small and medium-sized enterprise financing is the bank and private loans, equity financing, the way of financing is relatively single. Bank loans affected by the credit policy, faces a long period of credit, and in the process of financing may need to provide sales mode of operation of the key factors, the name of the company, and key customer contracts, key customers, which will make the company's business secrets loss, for big bank loans will oversee the company's behavior that reduces the company's own operating room, while private borrowing is not standardized, easily governed by the law. Customer service is to rely on the way back the assets market value as the standard, can improve the financing rate, reduce the degree of information loss.
Two, the financing of customer service and leaseback the tax treatment of the new regulations
(a) the sale of the Party (the lessee) of the value-added tax and business tax treatment
"Notice of the State Administration of Taxation on the financing of customer service and leaseback sale of assets by the lessee in the relevant tax issues" (the State Administration of Taxation Notice 2010 No. thirteenth) first stipulates: "the tax related provisions, the lessee the sale of assets by financing customer service leaseback, does not belong to the value-added tax and the business tax levy does not levy value-added tax and business tax."
(two) the value added tax and business tax of the transferee (lessor)
According to the "announcement of the State Administration of Taxation on the financing of customer service and leaseback sale of assets by the lessee in the relevant tax issues" (the State Administration of Taxation Notice 2010 No. thirteenth) regulations, lease leaseback financing customer service sell assets, asset ownership and ownership of assets associated with all the rewards and risks are not completely transferred. From the view of customer service has changed the past form of leaseback behavior, asset sale and leaseback as the same transaction, therefore, tax treatment is no longer divided into the sale and lease of two business, does not belong to the levying scope of VAT and business tax. But does not levy value-added tax and sales tax is relative to the seller (the lessee), the transferee (lessor) is still in accordance with the relevant financial leasing business tax collection.
(three) the disposal of the enterprise income tax of the seller (the lessee)
"Notice of the State Administration of Taxation on the financing of customer service and leaseback sale of assets by the lessee in the relevant tax issues" (the State Administration of Taxation Notice 2010 No. thirteenth) article second: "according to the current enterprise income tax law and the relevant provisions of the financing income determination, customer service and leaseback, the behavior of the sale of assets, not recognized as sales revenue to finance lease assets, according to the book value of the lessee before the original sale as the tax basis of depreciation. During the lease period, the lessee pays part of the interest paid to the finance, as a corporate finance charge in the pre tax deduction."
Based on this provision, financing customer service industry back in accordance with the following three conditions for treatment of corporate income tax:
First, due to the lessee the sale of assets, asset ownership and ownership of assets associated with all the rewards and risks are not completely transferred, according to the current enterprise income tax law and the relevant provisions of the financing income determination, customer service and leaseback, the behavior of the sale of assets, does not meet the revenue recognition criteria, therefore, does not confirm the sales revenue.
Second, the selling party (the lessee) still before the sale of the original book value as the tax base of depreciation, depreciation is also the same treatment did not occur as customer service leaseback behavior is still the same, continue to own assets depreciation.
Third, the interest part of the financing lease payments, as the financial expenses to be deducted.
Shenyang machine tool was founded in May 1993, mainly engaged in machinery and equipment manufacturing, machine tool manufacturing, machining and other services. In February 2, 2009, Shenyang issued a notice to the bank machine, apply for customer service lease leaseback financing, financing amounted to 200 million yuan, for a period of 4 years. Announcements, the company set out the assets book value 249 million 850 thousand yuan, 224 million 140 thousand yuan and net book value