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Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes

author:Zhonghui Xinda
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes

Announcement of the Yongxin County Taxation Bureau of the State Administration of Taxation on the Service of the Notice of Tax Matters

Release time: 2024-06-24

Source: Yongxin County Taxation Bureau

Yongxin County Yituo Enterprise Management Consulting Center (Limited Partnership) and other 4 units:

According to the risk suspicion reminder issued by the provincial bureau, your unit has the tax risk of not truthfully declaring income and underpaying taxes, and you are hereby ordered to submit relevant information such as stock reduction, fund delivery order, cost and expense details before June 2024 to the Second Taxation Branch of the Yongxin County Taxation Bureau of the State Administration of Taxation for tax inspection before June 29, 2024. Due to the inability to serve by other service methods, in accordance with the provisions of Article 106 of the Detailed Rules for the Implementation of the Law of the People's Republic of China on the Administration of Tax Collection, the Notice of Tax Matters is hereby announced to your unit.

Please go to our bureau in time to collect the original tax documents, and provide relevant tax-related information in a timely manner as required, otherwise, it will be deemed to have been delivered within 30 days from the date of the announcement, and at the same time, your unit will be deemed to have fled and lost contact if it fails to provide tax-related information as required.

The announcement is hereby made.

Appendix 1: Notice on Service of Tax Documents (No. 2 of 2024)

Attachment 2: Notice of Tax Matters

Yongxin County Taxation Bureau of the State Administration of Taxation

June 24, 2024

Background of the event and the reduction of holdings

According to the relevant announcements of listed companies, Yituo Partnership, Yicheng Partnership, Yidao Partnership, and Yifa Partnership are the equity incentive shareholding platforms for key employees of the listed company SIE Information (300687) before listing, and the source of shares is the shares issued before the initial public offering of SIE Information (including the shares that have increased due to the conversion of capital reserve into share capital).

According to the announcement, in May 2014, Zhang Chengkang transferred 5.00% of his capital contribution (500,000 yuan contribution) and 2.00% of the capital contribution (200,000 yuan contribution) held by SIE Co., Ltd. to Yidao Investment (3 million yuan invested by partners) and Yifa Investment (1.2 million yuan invested by partners) respectively. The consideration for this equity transfer is 6 yuan/capital contribution.

According to the announcement, on July 25, 2014, SIE Co., Ltd. increased the registered capital of the company by 1,111,110 yuan, which was invested by Yituo Investment and Yicheng Investment by 3,333,000 yuan, Yituo (partner contributed 3,333,000 yuan) corresponding to the registered capital of 555,555 yuan, and Yicheng (partner contributed 3,333,000 yuan) corresponding to the registered capital of 555,555 yuan, and the premium part totaled 5,554,900 yuan included in the capital reserve. The consideration for this capital increase is 6 yuan per capital contribution.

On December 1, 2015, SIE Co., Ltd. converted the company's net assets of 172,280,319.44 yuan as of October 31, 2015 into 60,000,000 shares at a ratio of 1:0.34827, with a par value of 1 yuan per share, and the remaining part was included in the capital reserve and changed to a company limited by shares as a whole.

After the share conversion, Yituo Investment directly holds 2,700,000 shares of the Company, Yicheng Investment directly holds 2,700,000 shares of the Company, Yidao Investment directly holds 2,430,000 shares of the Company, and Yifa Investment directly holds 972,000 shares of the Company.

Before and after the public offering of SIE, the number of shares held above has not changed.

The IPO issue price of SIE is 22.14 yuan per share, which corresponds to the issue price-earnings ratio: 22.99 times. Listing location: GEM of Shenzhen Stock Exchange. The listing time is August 3, 2017, according to the relevant provisions of the Company Law of the People's Republic of China, the shares issued before the company's public offering of shares shall not be transferred within one year from the date of listing and trading of the company's shares on the stock exchange. The shares held by the above four companies have been lifted from the restriction on August 8, 2018.

SIE's 2017 equity distribution plan, with capital reserve to all shareholders for every 10 shares to increase 8 shares, the distribution object is as of the afternoon of May 31, 2018, after the close of the Shenzhen Stock Exchange, all shareholders of the company registered in the Shenzhen Branch of China Securities Depository and Clearing Co., Ltd. The transferred shares will be directly credited to the shareholders' securities account on June 1, 2018, and the shares held after the conversion will be:

Yituo 4,860,000, holding 4,118,460 at the end of the year after the reduction

Yicheng 4,860,000, holding 3,966,500 at the end of the year after the reduction

Yidao 4,374,000, holding 3,563,980 at the end of the year after the reduction

Yifa 1,749,600, holding 1,394,300 at the end of the year after the reduction

Reduction in Q4 2018:

Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes

SIE's 2018 equity distribution plan is: 5 shares for every 10 shares to all shareholders from capital reserve, and the distribution object is all shareholders of the company registered in Shenzhen Branch of China Securities Depository and Clearing Co., Ltd. after the close of the Shenzhen Stock Exchange on the afternoon of May 30, 2019. The transferred shares were directly credited to the shareholders' securities account on May 31, 2019, and the shares held after the conversion are: Yituo 6,177,690 Yicheng 5,949,750 Yidao 5,345,970 Yifa 2,091,450

From May to June 2020, the four partnerships moved from Guangzhou to Yongxin County and changed their current names.

From May to June 2020, the investors of the 4 partnerships were changed from the shares directly held by individuals to the newly established 8 partnerships in Laibin City, Guangxi, each of which was held by two Laibin partnerships, and the Laibin partnerships were held by multiple individuals (who should be employees).

In October 2020, the investors of the four partnerships were changed from two partnerships to individuals holding less than 1% and Shanghai Fengtuo Management Consulting Partnership (Limited Partnership) holding 99% of the shares. (Shanghai Fengtuo Management Consulting Partnership (Limited Partnership) moved from Shanghai to Beiliu City, Yulin City, Guangxi Province in March 2021, and its name was changed to Beiliu Fengtuo Management Consulting Partnership (Limited Partnership), with 70% of the shares held by Cai Shenglong, an employee of the company, and 30% of the shares held by Chen Gang.)

Reduction in 2020:

Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes
Tax-related cases: the shareholding platform reduced its holdings, and the provincial tax bureau pushed the risk of underpayment of taxes

After the reduction in 2020, none of the four partnerships held shares in SIE.

https://jiangxi.chinatax.gov.cn/art/2024/6/24/art_31143_1609578.html

(Source: Tax Accountant Wan Weihua)