Port communicationInterpretation of the two accounting points for the deduction of financial lease differences (recommended useful information) "Ministry of Finance、Notice of the State Administration of Taxation on Comprehensively Launching the Pilot Program of Replacing Business Tax with Value-Added Tax (Caishui [2025] No. 36)，Qualified financial leasing companies (hereinafter referred to as leasing companies) engage in financial leasing business，The borrowing interest it pays to the bank can be derived from the entire price and premiums collected for providing financial leasing services or financing sale and leaseback services.
cost
deduction。
This provision avoids the impact on leasing companies caused by loan interest not being able to deduct input tax.，Reduces the tax burden of leasing companies to a certain extent。at present，Leasing companies mainly focus on financial leasing, direct leasing and sale-leaseback of tangible movable assets.，Some leasing companies also engage in commercial factoring business related to their main business.。
According to the provisions of Finance and Taxation [2025] No. 36，Direct rental business，The value-added tax rate is 17%；Sale and leaseback business，Pay VAT on loan services，The tax rate is 6%；Commercial factoring business is calculated and paid VAT at 6%。Deduction of the difference in borrowing interest from leasing companies，Pay attention to the timing of the difference deduction and the calculation of the amount of the difference deduction.。
Difference Deduction Time Current selection of difference deduction time，There are three views：1、During the contract period, the leasing company shall accrue deductions during the loan contract period.，Calculate the amount of difference that can be deducted in each period according to the borrowing conditions，When collecting rent, file a tax return on the amount after deducting accrued interest.。If the leasing company collects rent from the lessee on a quarterly basis，Bank borrowing is a one-time repayment of principal and interest upon maturity。The accrued borrowing interest is deducted when rent is collected quarterly.。
This method can ensure that the leasing company's tax burden is even during the contract period.，Reflects the actual tax burden borne by the leasing company in providing leasing business during the current period。But with the Finance and Taxation [2025] No. 36
Require
The preconditions for "payment" are not met，Difficult to be recognized and accepted by tax authorities。2、Deductions are made when paying interest. The leasing company shall declare the full amount of deductions in the current period when paying interest to the bank.。
This method can easily lead to uneven tax burdens on leasing companies.，The current tax burden on interest payments is lower，Tax burden is higher at other times，The nominal tax burden deviates from the actual situation。This situation will affect the leasing company's ability to enjoy the immediate refund policy if the tax burden exceeds 3%.，If in the current period when the difference is not deducted，Tax burden exceeds 3%，The leasing company enjoys a tax-and-refund discount。But for the entire project period，The actual tax burden may be less than 3%。
at the same time，The date of payment is used as the time to deduct the difference.，It is easy to ignore the timeliness of obtaining certificates。Didn't get invoice，It is also impossible to accurately fill in the "Service、List of deductions for differences between real estate and intangible assets" (this schedule
Require
Enter the invoice code of the difference deduction invoice in detail、Invoice number、Invoice amount and other information)，There is a risk that the declaration system cannot pass the review。
- The leasing company will deduct the difference in the month when the interest is paid and the interest certificate is obtained (the interest certificate for domestic borrowing is an invoice).，The interest voucher is obtained later than the actual payment，The time when the certificate is obtained shall prevail。This operation is in line with the premise of "payment" in the Finance and Taxation [2025] No. 36 document，It also meets the requirements of obtaining "valid certificate"
Require
。The shortcomings are similar to point 2，It is easy to cause the nominal tax burden to deviate from the actual tax burden。
Leasing company with little business，Attention should be paid to the coordination of the pace of interest payment and rent collection。Avoid being unable to deduct interest due to early declaration、There is no taxable income at the time of subsequent deductions, resulting in the inability to fully enjoy the policy benefits.。Difference deduction amount 1、Deduction of interest on special borrowings Special borrowings shall be deducted based on the actual interest paid。For example, if the leasing company borrows 20 million yuan from the bank,，The loan contract stipulates that the funds can only be used for lending for Project A.。
Then the interest on the loan can be deducted in the current period.。If A is a direct rental project，Then the sales tax deduction rate is 17%；For example, A is a leaseback project (leaseback in this article specifically refers to the financing sale and leaseback that will occur after April 30, 2025)，Then the sales tax deduction rate is 6%。2、Deduction of interest on general borrowings General borrowings with no restrictions on use，If it can be matched to a specific project，Borrowing interest can be deducted from project income.。
For example, the leasing company has direct leasing project A corresponding to bank loan a1，Leaseback project B corresponds to bank borrowing b1，There are no restrictions on the use of funds for the two bank loans.。A1 and A can be realized in the leasing company accounting、Exact match between b1 and B。When filing a tax return，The interest on the a1 loan is directly deducted from sales with a tax rate of 17%，b1 Borrowing interest is directly deductible from sales with a tax rate of 6%。
- The difference is deducted in the capital pool mode. In the capital pool mode，Because the borrowing interest cannot be matched with the project，Need to be apportioned according to a certain method。what method to use，There are currently no unified regulations。
In practice, there is the rent balance method (based on the calculation of the uncollected rent balance of the project at the end of the month)、Principal balance method (based on the uncollected principal balance of the project at the end of the month)、Rent occupied days method (calculated based on the product of the project's rental balance and the actual number of occupied days in the month) and principal occupied days method (calculated based on the product of the project principal and the actual number of occupied days in the month), etc.。
The proportion of apportionment is different under different calculation methods.，This will lead to varying degrees of discounts enjoyed by leasing companies.。Leasing companies should consider their own actual conditions，Choose the appropriate apportionment method。The selection of allocation method should be one that can reasonably reflect the actual capital cost of each project.。Financial leasing upstream docking with financial capital，Downstream services to the real economy。
driven by policy，has developed vigorously in recent years，The level of financing costs、The size of tax incentives (difference deductions) directly affects the development speed of the industry。Getting back to your roots in working in finance、In the context of serving the real economy，Standardized tax treatment is conducive to the healthy development of the financial leasing industry。
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