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误享税收优惠待遇 外企更正申报补缴13.4万元_我的网站

A |     TAIPEI, Taiwan -- Russian President Vladimir Putin arrived in Beijing on Tuesday for a visit that underscores China’s support for Moscow during its war in Ukraine as well as Russian backing for China's bid to expand its economic and diplomatic influence abroad.The two countries have forged an informal alliance against the United States and other democratic nations that is now complicated by the Israel-Hamas war. China has sought to balance its ties with Israel against its relations with Iran and Syria, two countries that are strongly backed by Russia and with which China has forged ties for economic reasons as well as to challenge Washington's influence in the Middle East.Putin's plane was met by an honor guard as the Russian leader began his visit that is also a show of support for Chinese leader Xi Jinping’s signature “Belt and Road” initiative to build infrastructure and expand China’s overseas influence.In an interview to Chinese state media, Putin praised the massive but loosely linked BRI projects.“Yes, we see that some people consider it an attempt by the People’s Republic of China to put someone under its thumb, but we see otherwise, we just see desire for cooperation,” he told state broadcaster CCTV, according to a transcript released by the Kremlin on Monday. Putin will be among the highest profile guests at a gathering marking the 10th anniversary of Xi’s announcement of the BRI project, which has laden countries such as Zambia and Sri Lanka with heavy debt from contracts with Chinese companies to build roads, airports and other public works they could not otherwise afford. U.N. Secretary-General António Guterres has praised the Chinese policy as bringing development to neglected areas. Asked by reporters Friday about his visit, Putin said it would encompass talks on Belt and Road-related projects, which he said Moscow wants to link with efforts by an economic alliance of former Soviet Union nations mostly located in Central Asia to “achieve common development goals.” He also downplayed the impact of China’s economic influence in a region that Russia has long considered its backyard and where it has worked to maintain political and military clout. “We don’t have any contradictions here, on the contrary, there is a certain synergy,” Putin said.Putin said he and Xi would also discuss growing economic ties between Moscow and Beijing in energy, high-tech and financial industries. China has also grown in importance as an export destination for Russia.Alexander Gabuev, director of the Carnegie Russia Eurasia Center, said that from China’s view, “Russia is a safe neighbor that is friendly, that is a source of cheap raw materials, that’s a support for Chinese initiatives on the global stage and that’s also a source of military technologies, some of those that China doesn’t have.”“For Russia, China is its lifeline, economic lifeline in its brutal repression against Ukraine,” Gabuev told The Associated Press. “It’s the major market for Russian commodities, it’s a country that provides its currency and payment system to settle Russia’s trade with the outside world — with China itself, but also with many other countries, and is also the major source of sophisticated technological imports, including dual-use goods that go into the Russian military machine.”Gabuev said that while Moscow and Beijing will be unlikely to forge a full-fledged military alliance, their defense cooperation will grow.“Both countries are self-sufficient in terms of security and they benefit from partnering, but neither really requires a security guarantee from the other. And they preach strategic autonomy,” he said.“There will be no military alliance, but there will be closer military cooperation, more interoperability, more cooperation on projecting force together, including in places like the Arctic and more joint effort to develop a missile defense that makes the U.S. nuclear planning and planning of the U.S. and its allies in Asia and in Europe more complicated,” he added. The Chinese and Soviets were Cold War rivals for influence among left-leaning states, but China and Russia have since partnered in the economic, military and diplomatic spheres. Just weeks before Russia’s invasion of Ukraine last February, Putin met with Xi in Beijing and the sides signed an agreement pledging a “no-limits” relationship. Beijing’s attempts to present itself as a neutral peace broker in Russia’s war on Ukraine have been widely dismissed by the international community. Xi visited Moscow in March as part of a flurry of exchanges between the countries. China has condemned international sanctions imposed on Russia, but hasn’t directly addressed an arrest warrant issued for Putin by the International Criminal Court on charges of alleged involvement in the abductions of thousands of children from Ukraine. ___Associated Press writer Jim Heintz in Tallinn, Estonia, contributed to this report.。    AI摘要      一韩国非居民企业因在华服务超183天构成常设机构，误享中韩税收协定免税待遇。经税务核查与辅导，该企业主动更正申报，补缴企业所得税及滞纳金约13.4万元。

B |          近期，税务部门在税收协定待遇后续管理工作中，查处一起非居民企业错误享受税收协定待遇案件。一家韩国非居民企业来华提供设备安装服务，因对境内服务期限判断失误，违规享受协定免税待遇，经税务辅导后主动更正申报，补缴企业所得税及滞纳金合计约13.4万元。    2025年，这家韩国非居民企业为境内某材料科技有限公司提供设备安装服务，并派遣工作人员入境开展业务。业务开展期间，企业自行判定符合条件，委托境内合作企业申报享受中韩税收协定营业利润免税待遇。

C | 2026年3月，税务部门开展非居民企业税收协定待遇后续管理，在仔细核查业务合同、人员出入境记录等资料后发现，该企业在境内实际提供服务时间累计超过183天，已构成境内常设机构，不再满足免税适用条件。    经过税务人员的政策宣讲与精准辅导，该企业认清涉税风险，主动完成更正申报，并补缴企业所得税及滞纳金。    案例点睛     《中华人民共和国企业所得税法》第三条第二款规定，非居民企业在中国境内设立机构、场所的，应当就其所设机构、场所取得的来源于中国境内的所得，以及发生在中国境外但与其所设机构、场所有实际联系的所得，缴纳企业所得税。    根据《中华人民共和国政府和大韩民国政府关于对所得避免双重征税和防止偷漏税的协定》规定，“常设机构”一语包括：缔约国一方企业通过雇员或者雇用的其他人员，在缔约国另一方为同一个项目或相关联的项目提供的劳务，包括咨询劳务，仅以在任何12个月中连续或累计超过6个月的为限。    本案中，韩国企业境内服务时长超183天，已构成常设机构，对应收入应在中国缴纳企业所得税，不能适用营业利润免税条款。（记者 林春长 通讯员 胡书伟 许静婷）。

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