PPP模式税收优惠政策研究（国别篇）

Examples

In Indonesia tax holidays are available forfive to ten years. In the Philippines, Non-Pioneer Enterprises can obtain a taxholiday of four years and a Pioneer Enterprise can obtain a tax holiday of sixyears. Thailand provides an exemption from tax for up to eight years.

2. Reduced Corporate Tax Rates

Overview

Here the corporate tax rate is reduced based on the type of activity and other parameters, such as the location or region of the country.

Examples

In Vietnam a concessional tax rate of 10% applies for the duration of the project. Reduced tax rates also apply inspecial economic zones in this country. In Malaysia entities with Pioneer Status are granted an exemption on 70% of Statutory Income. Companies locatedin special regions such as Sabah, Sarawak and the designated Eastern Corridorof Peninsular Malaysia are granted a tax exemption on 85% of Statutory Income.

3. Accelerated Capital Allowances and Investment Allowances

Overview

The entity is allowed to write-off capitalcosts over a period of time shorter than the economic life of the asset. The present value of the expenditure is increased by allowing the deduction at a time closer to the investment.

Examples

This is one of the most common taxincentives relevant to infrastructure investment. A good example of this incentiveis found in Malaysia. Here an investment allowance of 60% of capitalexpenditure is available. This rises to 80% in special economic zones such as Sabah, Sarawak and the designated Eastern Corridor of Peninsular Malaysia. Malaysia also offers an infrastructure allowance and an industrial building allowance. The infrastructure allowance can be offset against up to 85% of statutory income in the year of assessment. Vietnam and Indonesia also allow for accelerated depreciation on infrastructure projects. Australia allows a write off of construction costs, usually over a 40 year period.

4. Location Based Incentives

Overview

Here tax incentives are targeted to apply to investments in specific regions within the country and are designed to stimulate infrastructure development in those regions.

Examples

The Philippines, Malaysia and Vietnam provide good examples of this incentive. In the Philippines there are special economic zones such as the Clark Special Tax Incentives for Public-Private Partnerships Michael Curran RMIT School of Accounting and RMIT APEC Research Centre 32 Economic Zone and Subic Special Economic Zone. A reduced tax rate of 5% on gross income earned is payable in lieu of all national and local taxes.Other incentives are also available such as reduced Value Added Tax and Customs Duty. Additional deductions are available for training expenses and labor expenses.Malaysia offers higher investment allowances in special economic zones such as Sabah, Sarawak and the designated Eastern Corridor of Peninsular Malaysia.Reduced tax rates also apply in special economic zones in Vietnam.

5. Reduced Taxes on Dividends and Interest

Overview

This incentive is designed to stimulate infrastructure investment by reducing the tax payable on dividends and interest received from companies involved in infrastructure development.

Examples

In Korea the Special Tax Treatment Control Act provides for a special taxation on interest from infrastructure bonds and special taxation of dividend income receivedby residents possessing stocks in a social fundamental facilities investment and lending company. In Australia it has been suggested that tax-exempt infrastructure bonds should be considered by the government.

6. Reduction in Withholding Tax

Overview

The reduction or elimination of withholding tax on dividends and interest for non-residents is designed to encourage foreign investment.

Examples

Vietnam provides a reduction of withholding tax on profits remitted overseas. Indonesia also provides a reduction inwithholding tax on dividends paid to foreign shareholders from 20% to 10%.

7. Carry Forward Losses

Overview

Infrastructure projects usually incur losses in the early years of operation. It is common for countries to allow these losses to be carried forward and offset against future income.

Examples

In Australia the government proposes that designated infrastructure projects will be able to uplift the value of project losses at the Government Bond rate and exempt these losses from the anti-avoidance provisions (the continuing of ownership test and the samebusiness test) thereby allowing them to be deducted in future years. The uplifting of the losses at the Government Bond rate will mean that the losses do not lose value over time. Indonesia and Vietnam allow losses to be carried forward for between five and ten years.

8. Deductions for Qualifying Expenses

Overview

Specific expenses are deductible in order to encourage and target specific investments.

Examples

In the Philippines extra deductions areavailable for training expenses and labor expenses.

9. Reduction in Indirect Taxes

Overview

In order to encourage investment, exemptions are given in respect of customs duties and import tax and otherindirect taxes, such as Value Added Tax. This is a common incentive and has been widely used to encourage infrastructure development.

Examples

In Korea acquisition tax and property tax are reduced for Public-Private Partnership infrastructure projects. Korea also provides for a reduction in Value Added Tax. In special economic zones of the Philippines, Value Added Tax and Customs Duties are reduced to zero. The Philippines also reduces Customs Duty on equipment, machinery and raw materialsand exempts companies from local taxes. In Malaysia, Stamp Duty remission is given on service agreements signed between companies and the government, thereby reducing transaction costs.

10. Other Related Incentives

Overview

A number of the countries surveyed have legislated a number of non-tax incentives to encourage infrastructure development. Although they are not specifically tax incentives, they are designed to encourage foreign investment.

Examples

Vietnam and Thailand have legislated to guarantee that infrastructure projects will not be nationalized

Vietnam has also provided guarantees to protect intellectualproperty rights

In Thailand The Investment Promotion ActB.E. 2520 permits skilled workers to be bought into the kingdom to work on investment promotion activities. The legislation also permits the ownership of land and the remittance of money abroad in foreign currencies

注：本文节选自墨尔本皇家理工大学会计学院及墨尔本皇家理工大学亚太经合组织研究中心发表的《Tax Incentives for Public-Private Partnerships 》。如遇索取完整版报告，可添加微信ID：695991686（此号为译税小编）。

【译税】是由一群热爱公益的财税学子发起、运营和维护的非营利项目，致力于学习和交流各类国际税收资讯。

如果您对我们的内容感兴趣，欢迎订阅关注我们的公众号。谢谢！

业务合作请联系：wuming_zyyx@163.com