ACCA P6（China）历年试题大全（2004年-2008年）

包含（2004年-2008年）ACCA P6（China）历年考试真题及答案，文件列表如下：
Dec-2004.PDF、Dec-2005.PDF、Dec-2006.PDF、Dec-2007.PDF、Dec-2008.PDF；
June-2005.PDF、June-2006.PDF、June-2007.PDF、June-2008.PDF；

Professional Level – Options Module, Paper P6 (CHN)
Advanced Taxation (China) June 2008 Answers
1 Report
To: The management of Nova Company Limited
From: Tax Advisers
Date: 2 June 2008
Subject: Customs duty and value added tax (VAT) implications of Newco’s export business
As instructed this report sets out the customs duty and VAT costs which would be incurred under the three business models being
considered.
(a) The VAT export refund rate for Product X is 13%
(1) Contract manufacturing
As all the finished products will be shipped out of China to the foreign consignor, the raw materials sourced outside
China by the consignor can be imported by Newco into China free of Chinese import duty and import (VAT) (i.e. they
may be bonded).
Further, under contract manufacturing, the processing fee income of Newco (the Processor) can be exempted from 17%
output VAT. However, the input VAT incurred by Newco on local purchases (e.g. local raw materials, utilities) cannot be
recovered nor refunded, thus this will become a real cost to Newco and should be charged to its cost of goods sold
(COGS).
Non-recoverable VAT = the input VAT incurred by Newco on local purchases (e.g. local raw materials, utilities):
i.e. (RMB 100 + RMB 100) x 17%= RMB 34
(2) Import manufacturing
Customs import duty and import VAT on imported raw materials can be exempted, provided that all the processed
finished goods are re-exported. As Newco will export all of Product X this exemption will apply.
Newco’s export sales income can be exempt from output VAT, and it can also receive from the Chinese tax authority a
refund of the input VAT incurred on local purchases (e.g. local raw materials, utilities). However, only if the refund rate
is 17%, will all of the VAT incurred on the local purchases be refunded. As the refund rate is lower than 17%, part of
the VAT incurred on the local purchases cannot be refunded, hence ‘non-refundable VAT’ which is a real cost to the
export manufacturer will arise. Therefore, non-refundable VAT calculated using the following formula should be charged
to the ‘cost of goods sold’ (COGS) of Newco.
Non-refundable VAT = (FOB value of the exported product – the value of import bonded raw materials) x (17% – the
applicable VAT refund rate for the exported product):
i.e. (RMB 2,000 – RMB 1,000) x (17% – 13%) = RMB 40
(3) Non-bonded export trade
Neither the customs import duty nor the 17% import VAT can be exempted on the imported raw materials.
As in (2) above, Newco’s export sales income can be exempt from output VAT, and it can also receive a refund of the
input VAT incurred on the purchase of local raw materials. However, again as the refund rate is lower than 17%,
non-refundable VAT will arise, resulting in a real cost to Newco.
Non-refundable VAT = FOB value of the exported product x (17% – the applicable VAT refund rate for the exported
product):
i.e. RMB 2,000 x (17% – 13%) = RMB 80
There is no provision for a refund on the import duty on importation and the whole amount of this becomes a cost to
the manufacturer.
Non-refundable import duty = Duty rate x value of imported raw materials:
i.e. 10% x RMB 1,000 = RMB 100
Conclusion
Based on the above, the first business model, contract manufacturing, incurs the least amount of non-refundable VAT and
Chinese import duty as such this should be the preferred business model for Newco to carry out the intended export business.
(b) The VAT export refund rate for Newco’s Product X drops to 0%
(1) Contract manufacturing
There will be no impact on the bonded tolling arrangement if the VAT export refund rate drops to 0%. The
non-recoverable VAT is therefore the same as that in (a) (1) above, i.e. RMB 34.
(2) Import manufacturing
If the refund rate drops to 0%, Newco cannot receive any refund of the input VAT incurred on local purchases of raw
materials and utilities from the Chinese tax authority.