Iii. Handling of items carried forward from previous years that have not been deducted before tax

The items carried forward from previous years have not been deducted before tax, such as advertising and business publicity expenses, employee education funds, etc., in the previous year's tax adjustment did not make the enterprise assets (liabilities) accounting cost and tax basis difference, so there is no difference in the liquidation of the enterprise back to the problem, in theory these items will never be deducted before tax.

case5:Ecompany2014Advertising expenses are incurred annually500RMB 10,000 yuan, pre-tax deduction is allowed in the current year100Ten thousand yuan and the rest400RMB yuan will be deducted for the year after it is carried forward indefinitely.Ecompany2014years12Month closed liquidation.Ecompany2014Annual accounting treatment:

Borrow: Operating expenses  5000000

      Loan: bank deposit  5000000

Difference analysis: AlthoughEThe company should increase the cost of advertising which has overspent2014Annual taxable income, but not causedEThe accounting cost of the company's related assets (liabilities) differs from the tax basis, thereforeEThe company does not need to consider the above business when calculating the liquidation income, that is, it does not need to adjust the taxable income amount accordingly.

There are some disputes in practice about whether the "asset realization income" generated in the process of liquidation of enterprises can be used as the calculation base for carrying forward and deducting the advertising expenses and business publicity expenses of previous years. I think, from the national tax letter [2009:388According to the structure of liquidation declaration form stipulated in Document No., there is no need to fill in "asset realization income" when reporting liquidation income. Therefore, "Asset realization income" It cannot be used as the calculation base for the deduction of advertising expenses and business publicity expenses carried forward in previous years.

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