การวางแผนภาษี ก่อนเลือกซื้อทรัพย์สิน
เมื่อกิจการมีกำไรสุทธิที่ต้องเสียภาษีเงินได้นิติบุคคลประจำปี การวางแผนภาษี สำหรับกิจการเพื่อลดภาระค่าใช้จ่ายทางภาษีเป็นสิ่งที่เจ้าของกิจการ ผู้ประกอบการ ต้องคำนึงถึงส่วนนึงของการทำธุรกิจ และหนทางนึงที่จะนำมาใช้เพื่อช่วยลดภาระทางภาษีให้น้อยลงก็คือการซื้อสินทรัพย์ แต่ทั้งนี้สินทรัพย์ในทีนี้จะกล่าวรวมไปถึงสินทรัพย์ที่สร้างหรือประกอบขึ้นเองอีกด้วย เมื่อทรัพย์สินที่ได้มานั้นก่อสร้างเสร็จขึ้นโดยสมบูรณ์แล้ว และต่อมามีรายการค่าใช้จ่ายเกิดขึ้นเกี่ยวข้องกับ ที่ดิน อาคารและอุปกรณ์นั้นๆ ก็จะถือเป็นต้นทุนของทรัพย์สินหรือค่าใช้จ่ายเพื่อนำมาประกอบการหักค่าใช้จ่ายทางภาษีได้มากยิ่งขึน
กิจการสามารถรับรู้ค่าใช้จ่ายที่เกิดขึ้นเป็นสินทรัพย์ได้ก็ต่อเมื่อเข้าเกณฑ์ของการปรับปรุงเพื่อให้สินทรัพย์นั้นๆ อยู่ในสภาพที่ดีขึ้นกว่าเดิมหรือสูงขึ้นกว่ามาตรฐานกำหนด เช่น การปรับปรุงอาคารเพื่อยืดอายุการใช้งาน การยกเครื่องของเครื่องจักรเก่าเพื่ออัพเกรดประสิทธิภาพของการทำงานให้สูงขึ้น ในส่วนนี้จะสามารถรับรู้เป็นสินทรัพย์ได้เมื่อพร้อมใช้งาน แต่หากการปรับปรุงดังกล่าวเป็นพียงเพื่อการรักษาสภาพของสินทรัพย์นั้นๆ ให้คงสภาพเดิม ส่วนนี้กิจการต้องรับรู้เป็นค่าใช้จ่าย อย่างไรก็ตามหากกิจการมีค่าใช้จ่ายอันเกิดขึ้นจากการเปลี่ยนแทนระยะเวลาหนึ่ง เช่น การเปลี่ยนแบตตอรี่ของเครื่องยนต์ การเปลี่ยนมอเตอร์ของเครื่องจักร ทดแทนของเก่าที่เสื่อมสภาพไป ส่วนประกอบเหล่านี้จะถือเป็นสินทรัพย์แยกต่างหาก เนื่องจากมีอายุการใช้งานไม่เท่ากับสินทรัพย์เดิมที่มีอยู่ เพื่อสะดวกต่อการควบคุมดูแล ประเมินมูลค่า คำนวณค่าเสื่อม จึงต้องแยกสินทรัพย์ออกจากกัน
เมื่อกิจการมีความต้องการสินทรัพย์เพื่อนำเข้ามาใช้ในการบริหารกิจการ สามารถเลือกวิธีการได้มาซึ่งสินทรัพย์หลายวิธีด้วยกัน คือ
1. วางแผนภาษี ก่อนเลือกซื้อทรัพย์สินด้วยเงินสด
การซื้อสินทรัพย์ด้วยเงินสด: การซื้อสินทรัพย์ถาวรในบางกิจการที่มีความสามารถในการชำระเงิน โดยกิจการอาจเลือกตัดสินใจซื้อสินทรัพย์เป็นเงินสด
ตัวอย่าง บริษัท M.F.N. ได้ซื้อเครื่องชงกาแฟ 1 เครื่องในราคา 200,000 บาท และชำระเป็นเงินสด อัตราภาษีมูลค่าเพิ่ม 7% บันทึกบัญชี ดังนี้
เครื่องชงกาแฟ
ภาษีซื้อ
เงินสด
บันทึกซื่อเครื่องชงกาแฟด้วยเงินสด
200,000
14,000
214,000
2. การวางแผนภาษี ก่อนการซื้อสินทรัพย์ด้วยเงินเชื่อ
การซื้อสินทรัพย์ด้วยเงินเชื่อ: กิจการบางแห่งอาจจะใช้วิธีการเลือกซื้อสินทรัพย์ถาวรด้วยเงินเชื่อ การชำระเป็นเครดิตซึ่งอาจจะมีระยะเวลา 7, 15, หรือ 30 วัน ล้วนขึ้นอยู่ตามแต่ละข้อตกลงระหว่างผู้ซื้อและผู้ขาย เพื่อให้กิจการหมุนเวียนสภาพคล่องของเงินสดในการดำเนินกิจการ
ตัวอย่าง บริษัท M.F.N. ได้ซื้อเครื่องชงกาแฟ 1 เครื่องในราคา 200,000 บาท เป็นเงินเชื่อและมีกำหนดชำระเงินภายใน 30 วัน อัตราภาษีมูลค่าเพิ่ม 7% บันทึกบัญชี ดังนี้
เครื่องชงกาแฟ 200,000
ภาษีซื้อ
เจ้าหนี้ค่าเครื่องชงกาแฟ
บันทึกซื่อเครื่องชงกาแฟด้วยเงินเชื่อ
200,000
14,000
214,000
เจ้าหนี้ค่าเครื่องชงกาแฟ
เงินสด
บันทึกชำระค่าเครื่องชงกาแฟ
214,000
214,000
3. การวางแผนภาษี ก่อนซื้อทรัพย์สินโดยการเช่าซื้อหรือผ่อนชำระ
3. การซื้อสินทรัพย์ด้วยการเช่าหรือผ่อนชำระ: เป็นอีกวิธีหนึ่งที่เป็นที่นิยม ก็คือการเลือกซื้อโดยการเช่าซื้อหรือการผ่อนชำระ เพราะเป็นวิธีการหมุนเวียนสภาพคล่องเงินสดของกิจการ โดยไม่ต้องใช้เงินสดทั้งก้อนในการจัดซื้อสินทรัพย์ แต่จะเป็นการค่อยๆ ทยอยชำระเงินเป็นงวดๆ จนกว่าจะครบกำหนด แต่วิธีการนี้กิจการต้องแบกรับภาระค่าดอกเบี้ยจ่ายจากการผ่อนชำระ
ตัวอย่าง บริษัท M.F.N. ได้ซื้อรถกระบะ 1 คัน ในราคา 600,000 บาท อัตราภาษีมูลค่าเพิ่ม 7% โดยวิธีการเช่าซื้อมีรายละเอียดดังนี้
1. 120,000 บาท
2. 12,000 บาท
120,000 บาท
12,000 บาท
คำนวณเงินที่ต้องชำระ
1. ชำระเงินดาวน์
2. ผ่อนค่างวด
120,000 บาท
576,000 บาท
รวมจำนวนเงินต้องชำระสุทธิ
696,000 บาท
การซื้อทรัพย์สินโดยการเช่าซื้อหรือผ่อนชำระตามมาตรฐานบัญชี ฉบับที่ 16 โดยสภาวิชาชีพบัญชี ให้ถือเอา “ราคาเงินสด” เป็นต้นทุนของสินทรัพย์นั้น และผลต่างของราคาเงินสดกับจำนานเงินที่ต้องผ่อนชำระให้ถือเป็นดอกเบี้ยจ่ายซึ่งจะทยอยตัดออกตามระยะเวลาที่ได้มีการผ่อนชำระในแต่ละงวด
ตามกฎหมายภาษีอากร พระราชกฤษฎีกาฯ ฉบับที่ 145 นั้น การเช่าซื้อทรัพย์สินโดยการผ่อนชำระเป็นงวดๆ ในแต่ละเดือน จะถือเอาราคาที่ตกลงซื้อขาย (ตามสัญญา) โดยไม่แยกดอกเบี้ยตามลักษณะเงินได้ตามมาตรา 40 (4) แห่งประมวลรัษฎากรเป็นต้นทุนของทรัพย์ ดังนั้น ราคาที่เกิดจากการเช่าซื้อสินทรัพย์ให้ใช้ราคาที่ตกลงซื้อขายกัน (696,000 บาท) เป็นต้นทุนของทรัพย์สินนั้น โดยนำทรัพย์สินนั้นไปคิดค่าสึกหรอและค่าเสื่อมราคาตามหลักเกณฑ์ที่กำหนดในพระราชกฤษฎีกาฯ (ฉบับที่ 145) และภาษีซื้อจะเกิดขึ้นตามค่างวดที่ถึงกำหนดชำระในแต่ละงวดซึ่งถือเป็นภาษีซื้อที่กิจการมีสิทธิขอคืนหรือเครดิตภาษีขาย แต่หากเป็น ภาษีซื้อรถยนต์ ที่เกิดจากการซื้อรถยนต์นั่งหรือรถยนต์โดยสารที่มีที่นั่งไม่เกิน 10 คน ภาษีซื้อดังกล่าวถือเป็นต้นทุนของรถยนต์นั้น การบันทึกบัญชีในกรณีถ้ารถยนต์ดังกล่าวหากเป็นรถกระบะซึ่งไม่ใช่รถยนต์นั่งหรือรถยนต์โดยสารที่มีที่นั่งไม่เกิน 10 คน
กรณีบันทึกตามหลักมาตรฐานบัญชี จะแสดงดังนี้
รถยนต์
ดอกเบี้ยจ่ายรอตัดบัญชี
ภาษีซื้อยังไม่ครบกำหนด
ภาษีซื้อ
เงินสด
เจ้าหนี้เช่าซื้อ
600,000
96,000
40,320
8,400
128,400
616,320
บันทึกการซื้อรถยนต์โดยการเช่าซื้อ
เจ้าหนี้เช่าซื้อ
ดอกเบี้ยจ่าย
ภาษีซื้อ
เงินสด
ดอกเบี้ยจ่ายรอตัดบัญชี
ภาษีซื้อยังไม่ครบกำหนด
12,840
2,000
840
12,840
2,000
840
ผ่อนชำระค่างวดครั้งที่ 1 ตัดดอกเบี้ย 2,000 บาท
กรณีบันทึกตามหลักเกณฑ์ตามพระราชฎีกาฯ ฉบับที่ 145 แสดงดังนี้
รถยนต์
ภาษีซื้อยังไม่ครบกำหนด
ภาษีซื้อ
เงินสด
เจ้าหนี้เช่าซื้อ
บันทึกการซื้อรถยนต์โดยการเช่าซื้อ
696,000
40,320
8,400
128,400
616,320
เจ้าหนี้เช่าซื้อ
ภาษีซื้อ
เงินสด
ภาษีซื้อยังไม่ครบกำหนด
ผ่อนชำระค่างวดครั้งที่ 1
12,840
840
12,840
840
ข้อสังเกต: กิจการจะต้องบันทึกบัญชีตามมาตรฐานการบัญชี
สิ่งที่ต้องระวังในการคำนวณกำไรสุทธิเพื่อเสียภาษีเงินได้นิติบุคคลเพื่อประโยชน์สูงสุดใน การวางแผนภาษี คือการบันทึกต้นทุนของสินทรัพย์ที่เกิดจากการเช่าซื้อหรือผ่อนชำระตามหลักการทางบัญชีต้นทุนของสินทรัพย์คือราคาเงินสด ในขณะที่ประมวลรัษฎากรคือเอามูลค่าทั้งหมดตามสัญญาเช่าซื้อหรือผ่อนชำระ ดังนั้น หากกิจการบันทึกบัญชีตามมาตรฐานการบัญชี เมื่อถึงรอบระยะเวลาปิดงบการเงินจะต้องปรับปรุงรายการดอกเบี้ยจ่ายและค่าเสื่อมราคาให้สอดคล้องกับวิธีการทางภาษีโดยการปรับปรุงกำไรสุทธิทางบัญชีให้เป็นกำไรสุทธิทางภาษีอากร (บวกกลับ) ในแบบ ภ.ง.ด.50
4. การซื้อสินทรัพย์โดยสัญญาเช่าระยะยาว (Leasing)
การเลือกซื้อทรัพย์สินให้เกิดประโยชน์ทางภาษีนั้น นอกจากวิธีที่กล่าวมาข้างต้น ยังมีอีกวิธีนึงที่นิยมเช่นเดียวกันก็คือวิธีลีสซิ่ง (Leasing) หรือเรียกว่าสัญญาเช่าระยะยาว เมื่อหมดสัญญาเช่ากิจการต้องตัดสินใจระหว่างจะซื้อสินทรัพย์ที่เข่าหรือไม่ ซึ่งในประเทศไทยนิยมใช้อยู่
2 วิธี คือ 1) สัญญาเช่าดำเนินงาน (Operating Lease) และ 2) สัญญาเช่าทางการเงิน (Financial Lease)
สัญญาเช่าทางการเงิน (Financial Lease)
เป็นสัญญาเช่าที่หากเมื่อสิ้นสุดสัญญาเช่าแล้ว กิจการอาจจะซื้อสินทรัพย์นั้นมาถือเป็นกรรมสิทธิ์ของกิจการได้ หากกิจการเลือกวิธีนี้จะถือว่าสินทรัพย์ที่เช่านั้นเป็นสินทรัพย์ของกิจการเมื่อมีการส่งมอบ และต้องนำมูลค่าสินทรัพย์ทั้งหมดมาถือเป็นสินทรัพย์ของกิจการตามข้อกำหนดของสัญญาเช่า ลักษณะของสัญญาเช่าทางการเงินจะต้องมีเงื่อนไขดังต่อไปนี้
- ผู้ให้เช่าต้องโอนกรรมสิทธิ์ให้แก่ผู้เช่าเมื่อสัญญาสิ้นสุดอายุการเช่า
- ให้สิทธิผู้เช่าสามารถซื้อสินทรัพย์ที่เช่าได้ในราคาต่ำกว่าท้องตลาดเมื่อสัญญาเช่าสิ้นสุดลง
- อายุของสัญญาเช่าต้องไม่น้อยกว่า 75% ของอายุการใช้สินทรัพย์ให้เช่า
- มูลค่าปัจจุบันของค่าเช่านับแต่วันเริ่มทำสัญญาต้องมากกว่าหรือเท่ากับ 90% ของราคาที่อาจขายให้กับบุคคลภายนอก
- ราคาตามบัญชี และราคาตลาดของสินทรัพย์ต้องมีราคาเดียวกัน
- ไม่มีผลกำไรหรือขาดทุน ณ วันทำสัญญา
ตัวอย่าง: บริษัท M.F.N. ได้เช่าเครื่องจักรเป็นเวลา 4 ปี โดยเริ่มตั้งแต่วันที่ 1 มกราคม 2564 เครื่องจักรมีราคาทุนเป็นเงิน 2,000,000 บาท กำหนดจ่ายค่าเช่าทุกต้นปีในวันที่ 1 มกราคมของทุกปี อายุการใช้งานของเครื่องจักร 4 ปี ไม่มีราคาซาก โดยกำหนดอัตราดอกเบี้ย 12% ต่อปี อายุสัญญาเช่าไม่ต่ำกว่า 75% การคำนวณหาค่าเช่ารายปีจะแสดงดังนี้
การซื้อทรัพย์สินโดยการทำสัญญาเข่าระยะยาวเป็นสัญญาเช่าทางการเงิน (Financial Lease) ในทางปฏิบัติตามประมวลรัษฎากรไม่ยอมรับเงื่อนไขวิธีทางการบัญชีตามมาตรฐานการรายงานทางการเงิน ฉบับที่ 16 ที่ถือว่าทรัพย์สินที่เช่าเป็นกรรมสิทธิ์ของผู้เช่าทันทีที่มีการส่งมอบทางภาษีอากรไม่ยอมให้ถือเป็นสินทรัพย์เนื่องจาก “ผู้เช่า” ยังไม่ได้ซื้อทรัพย์สินที่เช่า ดังนั้น ค่าเช่าที่จ่ายจึงถือเป็นค่าใช้จ่ายในการคำนวณกำไรสุทธิ ตามรอบระยะเวลาบัญชีนั้นซึ่งเป็นลักษณะของสัญญาเช่าดำเนินงาน (Operating Lease) ดังนั้น หากกิจการเลือกบันทึกวิธีการบัญชีตามหลักเกณฑ์ทางบัญชีดังกล่าวจะต้องมีการปรับปรุงกำไรสุทธิทางบัญชีให้เป็นกำไรสุทธิทางภาษีอากรเพราะรายจ่ายที่นำไปคำนวณกำไรสุทธิไม่เท่ากันระหว่างวิธีทาการบัญชีและวิธีทางภาษีอากร
ดังนั้น หากกิจการซื้อทรัพย์สินโดยการทำสัญญาเช่าระยะยาวและเป็นสัญญาเช่าทางการเงิน (Financial Lease) ที่เข้าหลักเกณฑ์ภาษีอากรดังกล่าว ค่าเช่าที่จ่ายในแต่ละเดือนหรือแต่ละรอบระยะเวลาบัญชีจะถือเป็น “รายจ่าย” ทั้งจำนวนในระยะเวลาบัญชีนั้น และค่าเช่าที่กิจการได้จ่ายในแต่ละงวดจะต้องหักภาษีเงินได้ ณ ที่จ่ายร้อยละ 5 เมื่อจ่ายค่าเช่าให้แก่ผู้ให้เช่าตามคำสั่งกรมสพากรที่ ท.ป.4/2528
สัญญาเช่าดำเนินงาน (Operating Lease)
เป็นสัญญาเช่าที่ผู้เช่านั้นต้องชำระค่าเช่าเป็นประจำทุกเดือน และกรรมสิทธิ์ในสินทรัพย์ที่เช่ายังคงเป็นของผู้ให้เช่า เมื่อครบกำหนดสัญญาเช่าผู้เช่าจะต้องคืนหรือส่งมอบสินทรัพย์ให้แก่ผู้ให้เช่า ตามมาตรฐานบัญชี ฉบับที่ 16 เรื่อง สัญญาเช่า ของสภาวิชาชีพบัญชี ได้กำหนดไว้ ดังนั้น สัญญาเช่าดำเนินงานจะมีลักษณะที่สำคัญ ดังนี้
- ผู้ให้เช่ามีกรรมสิทธิ์ในสินทรัพย์ให้เช่า ซึ่งจะได้รับประโยชน์จากการให้เช่าสินทรัพย์ นั้น
- ผู้เช่าไม่มีสิทธิซื้อสินทรัพย์เมื่อสิ้นสุดสัญญาเช่า
- สามารถบอกเลิกสัญญาเช่าได้ทั้ง 2 ฝ่าย
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ตัวอย่าง บริษัท M.F.N. ได้เช่าอาคารเมื่อวันที่ 1 มกราคม 2565 มีกำหนดระยะเวลา 3 ปี เจ้าของอาคารคิดค่าเช่าเท่ากันทุกปี ปีละ 2,000,000 บาท โดยจะต้องจ่ายค่าเช่าทันที่ทั้ง 3 ปีเป็นเงินทั้งสิ้น 6,000,000 บาท
บันทึกบัญชีทางด้านผู้เช่
1. บันทึกค่าเช่าทั้ง 3 ปี
เดบิต ค่าเช่าจ่ายล่วงหน้า
เครดิต ค่าเช่าจ่ายล่วงหน้า
6,000,000
6,000,000
2. บันทึกโอนค่าเช่าจ่ายล่วงหน้าเป็นค่าใช้จ่ายสำหรับปี
เดบิต ค่าเช่าจ่าย
เครดิต ค่าเช่าจ่ายล่วงหน้า
2,000,000
2,000,000
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