Recently, the employee shareholding platform "company into a partnership" was recovered 2.5 billion yuan of tax caused widespread concern. The initial intention of building a shareholding platform is to enjoy local tax incentives to save tax while maintaining the stability of the shareholding of listed companies, but with the precise focus of individual tax regulation on high-income groups, the local illegal tax approval and financial return policy of extensive and in-depth cleanup, the listed companies have to dismantle all kinds of shareholding platform. In this paper, we would like to make a reminder of the four major tax-related risks of listed companies' dismantling of shareholding platforms, and taxpayers should take this as a precautionary measure.

REITs, or real estate investment trusts, refers to a kind of investment fund that raises funds from investors through the issuance of income certificates to form fund property, which is handed over to a professional investment organization to invest in, manage and operate real estate with relatively stable returns, take the returns generated from real estate as the main source of income and allocate the vast majority of the returns to investors in a timely manner. Since April 2020, China is piloting real estate investment trusts (infrastructure REITs) in the infrastructure sector, with investment scope including toll roads, industrial parks, warehousing and logistics, sewage treatment, clean energy, guaranteed rental housing and other infrastructure.2023 On March 7, 2023, the Securities and Futures Commission (SFC) issued new regulations to expand the scope of investment, expand the participation of the main body, and optimize the audit and registration mechanism to promote the further development of REITs. In view of this, this paper interprets the tax arrangements involved in REITs based on the current tax regulations, and points out the risks and responses.

Recently, the employee shareholding platform "company into a partnership" was recovered 2.5 billion yuan of tax caused widespread concern. The initial intention of building a shareholding platform is to enjoy local tax incentives to save tax while maintaining the stability of the shareholding of listed companies, but with the precise focus of individual tax regulation on high-income groups, the local illegal tax approval and financial return policy of extensive and in-depth cleanup, the listed companies have to dismantle all kinds of shareholding platform. In this paper, we would like to make a reminder of the four major tax-related risks of listed companies' dismantling of shareholding platforms, and taxpayers should take this as a precautionary measure.

After an equity investment partnership loses its authorized tax status, its income tax rate on equity transfers can be up to 35%, which is a loss of tax advantage compared to direct individual shareholding. However, dismantling the shareholding platform to revert to individual shareholding status also faces the severe risk of partnership liquidation tax. Against this background, the relevant partnership-type shareholding platforms may consider adjusting the type of enterprise and applying policies such as the Circular of the Ministry of Finance, the State Administration of Taxation, the Development and Reform Commission, and the Securities and Futures Commission on the Issues of Income Tax Policies for Individual Partners of Venture Capital Enterprises (Cai Shui [2019] No. 8), to reduce the cost of the tax burden.

The third review draft of the revised Company Law was submitted to the Standing Committee of the 14th National People's Congress for deliberation on August 28, 2023, in which it was proposed to "improve the registration system for the subscription of registered capital, and stipulate that the amount of capital contributed by the shareholders of limited liability companies shall be paid in full within five years from the date of the establishment of the company." At the same time, Article 53 and Article 88, Paragraph 1 of the Second Review Draft of the Company Law provide for the accelerated expiration of the time limit for shareholders' capital contribution triggered by the maturity of the debt, as well as the original shareholders' supplemental liability for the unpaid portion of the transferred equity, increasing shareholders' liability for the unpaid portion of the capital contribution, which shows the trend of the Company Law to improve the shareholders' responsibility for the capital contribution, and to safeguard the interests of the creditors. Once the above provisions come into effect, for shareholders who wish to continue to operate the company but are short of capital flow, reducing the registered capital may be the only way for the enterprise to survive. However, most enterprises still have doubts about whether the process of capital reduction involves the declaration of enterprise income tax and individual income tax, and they do not understand the differences in tax laws and financial rules related to capital reduction, and they lack the awareness of tax declaration of "repayment in kind", which leads to a lot of tax problems in the process of capital reduction by shareholders. This article attempts to analyze the tax types involved in the process of capital reduction and divestment, and discusses the risks that may exist in the application of the tax law.

Guarantee system is a common means of credit enhancement in civil and commercial legal relations, which is of great significance to the financing and development of enterprises. In the field of tax administration, the tax guarantee system also has an important role that cannot be ignored, and it has positive significance in safeguarding the national tax collection and promoting the effective exercise of taxpayers' right to relief. This article is intended to analyze the common disputes in practice from the applicable circumstances of tax guarantee for reference.