油气资源国税费制度对我国海外油气投资的敏感性分析

    Sensitivity analysis of tax policy of oil and gas resource countries to China's overseas oil and gas investment

    • 摘要: 基于油气稳供保供的战略规划,海外油气投资项目稳中有进。为降低海外油气投资的外部经济风险,亟需探究影响投资效益的税费成本制约因素,降低企业税费成本负担而实现收益最大化。其中,厘清油气资源国的税费制度、制定合理的税费减免和规避策略,是提升海外油气投资的经济效益水平的关键路径。因此,本文以非洲油气资源国税费制度为例,基于建设和运营环节,系统梳理了油气投资的相关税种并构建了税费框架,结合东非某国A原油管道算例测度了关税、增值税、营业税及企业所得税等流转税和所得税影响内部收益率的敏感性程度,得出了关税与增值税存在“双重促进效应”,营业税存在“收入效应”与“替代效应”。结合税费框架,统筹油气勘探、开采、管输、炼化及销售等环节,提出了税费梳理和规划、减免和规避、风险防范稽查等免税策略与避税建议,为海外油气投资的税费商务策略优化提供借鉴。

       

      Abstract: Based on the strategy to stabilize the supply of oil and gas, the overseas investment projects of oil and gas have been proceeding steadily.In order to reduce the external economic risks of overseas oil and gas investment, it is significant to explore the constraints on tax which affect investment efficiency, and to reduce corporate's tax costs thus maximize its return.Clarifying the tax system and formulating reasonable tax reduction and evasion strategies are crucial to improve the economic efficiency of overseas investment.Therefore, this article takes the African resource national taxation system as an example, first to sorts out the relevant taxes under the construction and operation stages, then constructs the taxation framework following with a calculation example of a crude oil pipeline of East Africa, in which the tariff, value-added tax, business tax, corporate income tax and other turnover taxes and the effect of income tax on the sensitivity of the internal rate of return are measured.Through the analysis, it can be concluded that tariffs and value-added tax have “double promotion effect”, and business tax has “income effect” and “substitution effect”.According to the tax framework, with thorough consideration of each stage on oil and gas exploration, extraction, pipeline transportation, refining and sales, this article proposed several tax exemption strategies and tax avoidance suggestions including tax sorting and planning, reduction and avoidance, and risk prevention audits, which are taxation for overseas oil and gas investment provide reference for business strategy optimization.

       

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