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一、《关于从事房地产开发的外商投资企业售后回租业务所得税处理问题的批复》(国税函[2007]603号)根据本文件的规定,从事房地产开发经营的外商投资企业以销售方式转让其生产、开发的房屋、建筑物等不动产.又通过租赁方式从买受人回租该资产,企业无论采取何种租赁方式,均应将售后回租业务分解为销售和租赁两项业务分别进行税务处理。企业销售或转让有关不动产所有权的收入与该被转让的不动产所有权相关的成本、费用的差额,应作为业务发生当期的损益,计入当期应纳税所得额。文件
I. Reply on the Issue of Income Tax Treatment of Sale and Leaseback of Foreign-invested Enterprises Engaged in Real Estate Development (Guo Shui Han [2007] No. 603) Pursuant to the provisions of this document, foreign-invested enterprises engaged in the real estate development and management business transfer their production through sales , The development of real estate such as houses, buildings, etc., and leasing the asset back from the buyer by way of leasing, no matter what kind of leasing mode the enterprise adopts, the sale and leaseback business should be decomposed into two businesses of sales and leasing respectively for tax treatment . The difference between the income from the sales or transfer of real estate and the costs and expenses related to the ownership of the real property transferred shall be recorded into the current taxable profit and loss as the profits and losses of the current period when the business occurs. file