浅议契约型私募投资基金税务处理的若干问题

Discussion on Handling Tax Affairs about Contractual Type Privately Offered Fund

私募基金作为近年来在我国逐步发展的新生事物,其本身的有关运作、监管规则尚不成熟完善,其税收有关规则更是存在许多空白和盲区。文章通过对私募基金交易结构和投资者、基金管理人、融资企业等有关主体分析,从纳税主体、应税事项、适用规则角度提出意见和建议。

Newly born and gradually developing in recent years, privately offered fund is still immature in regulations about operation and supervision, with much blankness of regulations about taxation in particu- lar. By analyzing the transaction structure and the main body including the investor, the fund manager as well as the financing enterprise, this paper puts forward comments and suggestions from aspects of taxpayer, taxable items and applicable rules.