中国企业投资加拿大矿业实务分析

    Practices of Chinese enterprises' mining investment in Canada

    • 摘要: 本文从加拿大税制、海外投资架构、境外中间持股公司设立和维护和在加拿大注册公司四个方面对在加拿大矿业投资实务进行了总结和分析,加拿大矿业投资主要涉及的税种包括企业所得税、资本利得税、预提税等。为使税负最优,多采用两种间接持股的海外投资架构,本文具体分析了两种架构的税负效果,并结合管理层级、成本及未来投资规划方面对两种架构进行了比较。境外中间持股公司通常设在香港和卢森堡,本文总结了设立、维护中的程序和要求,以及适用的税制。除购买矿业公司股权外,也会在加拿大设立公司开展矿业投资、风险勘查等业务,文章提示了设立时通常关注的重要事项。

       

      Abstract: This paper summarizes and analyses mining investment practices in Canada from 4 aspects including Canadian taxes,oversea investment framework,establishing and operating intermediate holding companies,as well as establishing a Canadian local company.Investment in Canada usually involves corporate income tax,capital gain tax and withholding tax etc.To optimize corporate’s tax cost,two kinds of indirect holding frameworks are usually adopted.The applied tax rate in oversea investment under the two frameworks are concretely analyzed here,according to which,together with the management levels and cost as well as future investment planning,comparisons are made between the two frameworks.Intermediate holding companies are usually established in Hong Kong and Luxembourg under the two frameworks.The process and regulations about registration and operation,and the applied tax policy are discussed in this paper.Besides acquiring share equity in Canadian mining companies,new companies are established in Canada to launch mining investment and venture exploration.Important issues regarding the establishment of a Canadian company are also mentioned here.

       

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