中国企业投资巴西的纳税筹划研究——以X电力集团为例

Research on Cross-Border Tax Planning of Chinese Companies Investing in Brazil——Take X Electric Power Corporation as an Example

近年来,中国企业对"一带一路"沿线国家的直接和间接投资不断增加,其中电力、铁路、通讯等基建施工类企业的对外投资比重较高。拉美地区是21世纪海上丝绸之路的自然延伸,巴西是拉美地区最有影响力的国家之一,也是中国企业对外投资的重要目的国。大型跨国公司的发展经验表明,采用合理的对外投资方式和经营结构,充分利用不同地区的税收优惠政策和税制差异,可以为企业节约成本,增强其国际竞争力。在综述相关文献和巴西税制的基础上,以X电力集团为例,对其在巴西进行直接和间接投资的组织形式、资金运作和生产经营方式进行设计,以达到帮助该公司降低税负的目的,并且为其他企业开展跨国纳税筹划提供借鉴。

There is an obvious increase in both direct and indirect outward foreign investment of domestic enterprises in "OBOR" countries in recent years, among which, investment in fundamental constructions like electric power, railway, and telecommunication account for a significant share. Meanwhile, the development experience of many multinational companies show that, companies can minimize their total tax burden and improve their international competition strength by making full use of tax differences and tax preference policies in different countries and regions, and properly managing investment modes and arranging their business organization. Latin-America is the natural extension of the Maritime Silk Road, and Brazil is one of the most important countries in Latin America, as well as a vital target country of outward foreign investment of many Chinese companies. This paper takes X electric power group as an example, and designs tax planning schemes for its direct and indirect investment modes in Brazil. This research can shed some lights on cross-border tax planning for similar Chinese companies.