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How to strengthen foreign trade risk management
Introduction: The formation of the concept of comprehensive risk management and the operating risks faced by enterprises under the conditions of China's developing market economy mainly refer to the impact of future uncertainty on enterprise operating objectives, which is commonly seen in the economic situation, market status, financial arrangements, production operations and many other aspects.
(1) Raise awareness of export tax refund risk management and actively prevent management risks
To prevent export tax refund management risks, it is mainly to prevent the risk of export tax fraud. The first thing is to improve the awareness of export tax refund risk prevention, enhance the understanding of the harmfulness of export tax refund risks and the necessity and urgency of strengthening risk prevention and control. In recent years, the State Administration of Taxation has issued multiple documents requiring state taxation departments at all levels to pay attention to and strengthen early warning analysis and evaluation of export tax refunds to prevent export tax refund management risks. And the risk prevention, early warning analysis, verification and evaluation of export tax refunds have been written into the "Working Standards for Export Tax Refund (Exemption) Management". State taxation departments at all levels should, while promoting export tax refund policies, carry out export tax refund risk prevention education to make tax personnel fully aware of the harmfulness of export tax refund risks, and conscientiously carry out export tax refund risk prevention, early warning analysis, and verification and evaluation. Guide export enterprises to establish internal risk control mechanisms to ensure policy approval, procedural compliance, and legal behavior, eliminate illegal behavior, and move forward toward the path of legal operation, strict compliance with tax laws, and healthy development.
(2) Further improve tax refund policies and regulations and raise the level of regulations
In 2012, the Ministry of Finance and the State Administration of Taxation sorted out and integrated the previously scattered export tax refund regulations and classified them into "Tax Refund Policy", "Tax Refund Management Measures", and in 2015 the State Administration of Taxation issued the "Export Tax Refund Management Work Specifications", which were revised in 2016. In the past two years, after the comprehensive implementation of the "business tax to value-added tax" policy, some policies and regulations regarding refunds and tax exemptions for exported labor services have been added. These regulations have many imperfections and imperfections. Some policies are not clear enough, difficult to implement, and confusing when implemented. To this end, it is recommended to further integrate and improve export tax rebate policies and management regulations at the national level, and upgrade the level of regulations. The State Administration of Taxation should request the National People's Congress or the State Council to formulate relatively comprehensive, systematic and complete export tax refund management measures in the form of laws or administrative regulations, and propose a universally binding code of conduct for tax refund-related departments and enterprises to effectively regulate exports. Tax refund management behavior.
(3) Improve the value-added tax management system and build a complete value-added tax chain
The value-added tax management system is the foundation of export tax refund management. Only by improving the VAT management system, building a complete VAT chain, and strengthening VAT collection and management can we fundamentally prevent export tax rebate risks. The first is to standardize the value-added tax preferential system. Eliminate preferential policies that break the value-added tax chain and ensure the integrity of the value-added tax chain. For those who really need support and grant VAT exemptions, policy measures that do not affect the integrity of the VAT chain should be adopted, such as collecting first and then refunding. The second is to standardize value-added tax deduction vouchers. Unify the VAT deduction vouchers, cancel other VAT deduction vouchers such as agricultural product purchase vouchers, and enterprises can only use special VAT invoices to make deductions, completely solve the problem of difficult control and management of input deductions for purchasing agricultural products, and curb fraudulent input tax The occurrence of deductions. The third is to improve the management of value-added tax and special invoices. Improve the standardization and uniformity of value-added tax policy implementation, strengthen value-added tax collection management, and strictly prevent and crack down on illegal and criminal activities such as falsely issuing special value-added tax invoices in accordance with the law.
(4) Reform the export tax refund management mechanism to prevent tax refund management risks
Reform the traditional management method of reviewing orders and reviewing votes, and replace manual comparison with computer automatic comparison review, shift the focus to the prevention and control of export tax refund risks, and strengthen anti-tax fraud monitoring and analysis. The first is to fully implement computer automatic comparison and review. Clarify the implementation of self-checking and self-reporting and legal responsibilities for tax refund declarations of export enterprises, improve the collection of special value-added tax invoice information, and use computers to compare and review export tax refund declarations with special value-added tax invoices, export customs declarations, foreign exchange write-offs, cargo waybills and other related information . The second is to establish and improve the risk early warning monitoring and management system. Establish an export tax refund risk management team, optimize the early warning monitoring operation process, improve the export tax refund early warning monitoring indicator system, quickly identify export tax refund risk points and monitoring points, and form a four-level monitoring network at the general administration, province, city, and county. The third is to implement professional management.
Carry out export tax refund risk response. For export enterprises with lower risk levels, the tax service department will supervise self-examination and rectification of the enterprises; for export enterprises with higher risk levels, the tax refund department and tax source management department will conduct desk audits, interviews, and evidence production. Conduct tax refund assessments through methods such as analysis, on-site verification, etc.; high-risk export enterprises will be handed over to the inspection department for inspection.
(5) Improve the inter-departmental coordination mechanism and strengthen inter-departmental collaboration
The management of export tax rebates is mainly based on whether the tax rebates declared by enterprises comply with policy regulations, export and purchase Review and judge whether the business is genuine. During the review process, relevant information needs to be checked to determine the authenticity of the business and whether it complies with policy regulations. This information needs to be provided by customs, foreign affairs administration, commerce, commodity inspection, freight forwarding, shipping and other departments. In other words, export tax rebates Management requires cooperation and assistance from relevant departments, otherwise it will be difficult to complete. To this end, inter-departmental coordination mechanisms should be improved at the national and provincial levels and clarified in the form of regulations. First, the cooperation responsibilities of each department should be clarified. The customs will increase the inspection rate of export commodities, strictly investigate and punish illegal activities such as empty box customs clearance, false exports, false customs declarations, and pay-to-pay operations, and provide timely and accurate customs clearance information to the tax authorities; the foreign exchange administration and banking departments must strengthen the collection and settlement of foreign exchange for export enterprises. management, severely crack down on and report abnormal foreign exchange collection and settlement behaviors to the tax authorities; the commerce department must pay close attention to the development trends of foreign trade exports, strengthen the management of export business qualifications, and promptly notify the tax authorities of enterprise registration and export trends; customs brokers, freight forwarders, and carriers The unit shall promptly, truthfully and accurately provide cargo shipment status and documentary information to the customs and taxation departments; the customs, commerce, foreign affairs administration and other departments, while supervising export enterprises, shall promptly report the registration status of export enterprises to the tax department. Second, information sharing between departments should be realized. Establish a regular exchange mechanism between relevant departments for registration information, customs declaration and export information, cargo shipment information, foreign exchange collection and settlement information, credit rating information, and violation investigation and punishment information. Third, a standardized collaboration mechanism should be established, and joint department meetings should be held regularly to inform, communicate, and analyze relevant situations, and coordinate to resolve relevant issues.
(6) Deepen the integrated management of tax collection and refund, and implement a "four-in-one" interactive management mechanism
The municipal and county (district) tax bureaus should improve and adhere to tax refund review, The four-in-one interactive management mechanism for export tax refunds, which combines early warning analysis, verification and assessment, correspondence management and tax collection and tax refund management, analysis and assessment, and inspection, plugs loopholes in the tax management of export goods and severely cracks down on illegal tax evasion activities. Collection, management, tax refund, inspection and other departments must connect tax collection and refund management through timely exchange of information, so as to institutionalize and regularize tax refund early warning analysis, evaluation and inspection. Any doubts or suspicions and clues of tax evasion discovered by the tax refund management department during daily management and tax refund review, early warning analysis and evaluation must be promptly reported to the management department for investigation and verification or transferred to the inspection department for investigation and punishment. When receiving inspection requests and cases transferred from the tax collection and tax refund management departments, the inspection department must quickly arrange for a comprehensive and in-depth inspection, and after the inspection, promptly report the problems discovered during the inspection and the inspection status to the competent bureau and tax refund management department. Departmental feedback for mutual coordination and improvement.
(7) Establish a scientific and strict information monitoring network and improve the export tax refund early warning analysis system
Due to the differences between tax departments across the country and customs, foreign exchange management, and export tax refund business related There is no computer networking among various departments such as banking, commerce, and cargo transportation, so it is not possible to make full use of information such as tax collection and refund, customs inspection and clearance, foreign exchange collection, bank exchange settlement, transportation and loading, and commodity inspection to coordinate transactions. The authenticity of goods exports and tax refunds are comprehensively monitored, so that some companies use fake export goods customs declarations, fake export tax stamps, false filing documents and false replies from individual tax authorities to defraud export tax refunds. As far as the national tax department is concerned, the tax collection and refund management systems currently in use include the Golden Tax Three-Phase Collection and Management System, the Anti-Counterfeiting Tax Control Audit and Assistance Investigation System, the Export Tax Refund Review System, the Export Tax Refund Early Warning Assessment System, and the Export Goods Tax Correspondence System. These systems are both There are imperfections and there is no effective integration and application.
In order to strengthen the early warning analysis and evaluation of export tax refunds, the State Administration of Taxation entrusted Dalian Longtu Company to develop the "Export Tax Refund Early Warning and Evaluation System". Judging from the application of this system, it is not ideal. It cannot be integrated with the third-phase Golden Tax Collection and Management System and the Golden Tax Collection and Management System. The export tax refund review system, the export goods correspondence system, and the anti-counterfeiting tax control audit and assistance system are fully and smoothly connected, but they fail to achieve early warning analysis with highlighted key points, accurate doubts, and accurate analysis, and their operability and practicality are poor.
To this end, it is recommended to pass legislation to establish a national export tax rebate management system and implement computer networking between tax refund authorities and customs, foreign exchange administration, banks, industry and commerce, commodity inspection, foreign trade authorities and taxation authorities. , forming a government export tax rebate electronic law enforcement management system to achieve full sharing of information resources among various departments (including registration and filing information, customs clearance information, freight information, foreign exchange collection and settlement information, special invoice issuance and certification audit information, special tax stamp information, tax collection and refund information), and timely and accurate exchange of information. Further standardize and improve the electronic export tax refund management system by integrating the Golden Tax Phase III system, the value-added tax anti-counterfeiting tax control system, the export tax refund review system, the export goods tax correspondence system, the export tax refund information transmission system, and the export tax refund early warning analysis and evaluation system. , network with relevant external departments, share information, build a highly unified, powerful and integrated tax management information platform, break the situation of information incompatibility and poor tax collection and refund information between regions, departments and various information management systems, and implement Automatic comparison, prompting and sharing of tax collection, tax refund and external information nationwide to promote daily monitoring and management and effectively prevent export goods tax management risks.
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