中国房地产企业应对疫情税务解决方案：短中长期视角
Tax solutions for Chinese real estate enterprises to deal with the impact of Covid-19: including short, medium and long-term perspectives
2020年初，由于新冠肺炎疫情，中国房地产企业普遍受到较大冲击。在税务领域房地产企业应当如何应对？如何利用契机对税务管理和价值提升进行深入思考和改善？毕马威提出了一系列解决思路，供大家参考。
At the beginning of 2020, Chinese real estate enterprises generally suffered big shocks because of coronavirus disease. How should real estate enterprises take measures in the tax field? How to use this opportunity to deeply consider and improve on tax management and value enhancement? KPMG has proposed a series of solutions for your reference.
一、 克服阵痛 税务助力：充分利用税务政策，降低负面影响
Part Ⅰ Overcome the difficulties by tax solutions: Fully implement tax policies to reduce negative impacts
根据我们的观察，一些企业未能充分利用税收政策改善税负和涉税现金流。
这可能是由于未充分了解税收政策和适用策略，或未能制定并完善涉税管理流程，或未能根据自身情况精准测算并对政策作出恰当的取舍。短期而言，我们建议房地产企业全面梳理疫情影响下的业务涉税场景以及税务政策，量身制定疫情应对税筹方案，降低负面财务影响。
We have observed that some enterprises failed to effectively fulfill tax rules and regulations that can reduce their tax burden and improve tax-related cash flow.
There are several reasons for this issue, for instance, the enterprises might not fully understand the tax policies and relating applicable strategies, or the enterprises might not be able to develop and improve the tax management processes; or the enterprises fail to do their tax calculation accurately according to their own conditions and make proper choices for the tax policies that suitable for the company.
In the prospect of short-term, we recommend that real estate enterprises should comprehensively review the tax-related business scenarios and tax policies under the influence of the Covid-19, in order to develop tailor-made tax plans that able to reduce negative financial impact from Covid-19.
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部分典型涉税场景 Example of typical tax-related scenarios |
关注税务问题 Tax issues raised |
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商业地产减租免租 Rent reduction or rent free for commercial real estate |
免租期能否免于视同销售，能否免纳房产税、土地使用税？ Would rent-free period be able to exempt from "deemed sales", and can Real Estate Tax(“RET”) and Land Use Tax(“LUT”) be exempted? |
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商业、物管企业获得补贴 Commercial and property management enterprises receive subsidies |
补贴收入是否需缴纳企业所得税和增值税？ Are these subsidies income subject to CIT (“Corporate Income Tax”)and VAT (“Value Added Tax”)? |
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酒店、文旅地产收入下滑 The decline of revenue in hotel and cultural tourism real estate. |
生活服务业疫情期可享受增值税免税。但免税业务对应的进项税需做转出处理。特定情况下，享受免税可能反而导致税负上升及现金流恶化。企业在什么情况下应主动放弃免税？ Certain service industries are able to enjoy VAT exemption during Covid-19 outbreak. However, the input tax corresponding to the VAT-exempted transactions cannot be credited. Under certain circumstances，tax exemption may lead to increased tax burden and worsened cash flow, so under what kind of situations should enterprise abandon applying for tax exemption policies? |
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住宅地产销售下滑毛利降低 The decline of sales in residential property leads to reduction in gross profit. |
是否有机会免于预缴土地增值税？ 所得税预计毛利率是否有机会下调？ 增值税是否有机会实现退税？ Whether there is a chance to be exempted from pre-payment of LAT(“Land Value-added Tax”) ? Are there any chances to lower the estimated gross margin for the purpose of pre-payment of CIT? Are there any opportunities for VAT refund? |
二、复苏重启 税务增值：增强流动性、提升融资能力和重组资产结构
Part Ⅱ Recovery and value adding through tax solutions: enhancing liquidity, financing capabilities and restructuring asset structure.
中期而言，渡过危机后，我们建议企业思考如何提高流动性，推动破局重启。
In the mid-term prospect, we recommend enterprises consider how to improve liquidity in order to kick-start the business after this crisis.
企业需要尽快提升融资能力。除了传统的关联方融资、银行借款等，类REITs（房地产信托投资基金）和CMBS(商业地产抵押贷款支持证券) 等存量资产证券化融资由于能有效盘活存量资产且资金成本相对较低，颇受房企青睐。从事基础设施物业的企业，还可申请发行公募REITs。然而，由于缺乏配套的税务政策，如何有效降低高昂的税负成本，是需要着重考虑的问题。
Enterprises need to improve their financing capabilities as soon as possible. Except for those traditional financing methods, such as financing from related-parties, bank loan, etc., securitization of assets such as REITs (Real Estate Investment Trust) and CMBS (Commercial Mortgage-backed Securities) are considered by real estate enterprises, as these methods can effectively raise fund with relatively low costs.
Enterprises engaged in infrastructure properties can also issue public-listed of REITs. However, due to lack of relevant tax incentives, how to effectively reduce high tax burden of REITs is a key issue that shall be considered.
现金流吃紧的房企可考虑剥离非核心资产或进行股权重组改善负债率，调整资产结构。资金雄厚的企业可利用机会以较低价格获得优质项目资源。重组并购业务中涉及复杂的税务问题，在设计方案时需要重点考虑税负成本，需求最佳筹划方案。
Real estate enterprises with tight cash flow may consider restructuration or disposal of non-core assets, in order to improve the debt ratio and optimize asset structure. Enterprises with strong capital can take advantage of this opportunity to acquire projects with high-quality at lower prices.
Restructuring, mergers and acquisitions bring in complex tax issues, therefore, tax planning shall be considered when designing the restructuring plan to achieve tax efficiency.
三、科技赋能转危为机：税务信息化提高税务管理效能
Part Ⅲ Empowered by technology, and turn crisis into opportunity: tax technology will enhance tax management/p>
危机之下，企业均深刻体会到税务信息化的重要性。房地产行业由于其业务的复杂性和集团化管理的特性，对税务管理要求较高，特别关注税务科技的应用。疫情缓解后，我们观察到不少房企的税务科技项目正加速推动。
Under the crisis, enterprises are deeply aware of the importance of tax technology. Due to the complexity of its business and the characteristics of group management, the real estate industry has extensive needs for tax management, especially the application of tax technology. After Covid-19 outbreak, we have observed that many real estate enterprises are accelerating tax technology projects.
短期来看，企业可在长期财税自动化规划框架下，选择“速赢”类的税务科技模块，小步快跑、分项推进，例如：
In the short-term view, enterprises can choose to implement items in "Quick-Win" tax technology modules, and gradually promote the modules step by step, in order to achieve a long-term framework for automation of tax management:
- 采购和费用报销模块
- Purchase and expense reimbursement module
- 发票管理模块
- Invoice management module
- 纳税申报自动化模块
- Tax filing automation module
- 税务统计分析模块
- Tax statistical analysis module
从长期看，房地产企业应借此契机全盘布局税务科技。在规划阶段，企业需要确定税务信息化目标、明确税务信息化范围、对各功能模块优先层级排序、评估信息化基础、设计整体方案、梳理涉税数据。在实施开发之前，企业需落实涉税数据标准化、业务场景标准化和计税规则标准化。
In the long-term prospect, it is suggested that real estate enterprises should take this opportunity to formulate their strategy of tax technology application. In the planning stage, enterprises need to determine the tax technology goals, clarify the scope of application, prioritize functional modules, evaluate their current IT structure, and then design the scheme and identify tax-related data.
Before the system development and implementation, enterprises need to standardize related business scenarios, tax-related data and relevant tax calculation formula.
新冠疫情对于房地产企业而言即是危机也是挑战，一方面在重重压力下企业如何应对，克服各方面困难，这可能影响到企业的生存和健康。另一方面，疫情也让企业有机会重新审视自身财税体系、业务布局和资产配置，企业应利用此契机加强“内功”。通过分享我们的思考和经验，我们希望协助更多房地产企业通过税务管理提升，获得更加强韧的内生能力，以新姿态迎接疫情冲刷后的房地产新格局。
The Covid-19 is both a crisis and a challenge for real estate enterprises. On the one hand, how enterprises respond and overcome difficulties under heavy pressure may affect the existence and healthy of the company. On the other hand, the Covid-19 also gives enterprises a break to re-examine their financial and taxation systems, business model and resource allocation. Enterprises should take this chance to strengthen their "Internal Strength". By sharing our insights and experience, we hope to assist more real estate enterprises to enhance on tax management and gain a stronger endogenous ability to meet the new pattern of real estate after the Covid-19 outbreak.
