1. Pilot significance
To lay the foundation for the establishment of a long-term mechanism for large amounts of cash management, that is to say, through the pilot of the three provinces and cities, sum up accumulated experience, and then it is possible to promote to the whole country.
According to the analysis of relevant bankers, this large amount of cash management is limited to the management of cash deposits and withdrawals. Bank transfers, including public-to-public, public-to-private, and private-to-private, are still managed by the "Report on Large-Amount and Suspicious Transaction of Financial Institutions" The Measures (People's Bank of China Order No. 3 of 2016) is regulated.
2. Time and place
The pilot will last for 2 years and will be first carried out in Hebei Province and then extended to Zhejiang Province and Shenzhen City.
Since July 2020, Hebei Province has begun a pilot project.
Starting from October 2020, Zhejiang Province and Shenzhen Municipality have begun pilot projects.
Why choose these three provinces and cities? The "Draft for Large Cash Management" released last year puts it this way:
The large-scale cash business management of banking financial institutions in Hebei Province has a good foundation. Zhejiang Province and Shenzhen City are both key cash-emitting regions in the country. Some industries in Zhejiang Province have outstanding current use of large amounts, and individual accounts have large current use. Shenzhen and Hong Kong The cross-border flow of RMB currency notes is common.
3. The starting point of the amount
Through the investigation and analysis of the pilot line, the starting point for the management of public accounts in all regions is 500,000 yuan, and the starting point for the management of private accounts is 100,000 yuan in Hebei Province, 300,000 yuan in Zhejiang Province, and 200,000 yuan in Shenzhen City.
The management business situation is mainly the counter business with cash physical handover, including the situation of self-service deposits and withdrawals through large-scale high-speed deposit and withdrawal equipment, and it is necessary to circumvent supervision and "pseudo-large-value cash transactions" for splits and hidden cash postings. The situation establishes preventive measures, not only monitoring a single transaction exceeding the starting amount, but also monitoring multiple transactions exceeding the starting amount.
Three provinces and cities' public accounts (including individual industrial and commercial households' public accounts) have cash access of more than 500,000 yuan, Hebei province's private account is more than 100,000 yuan, Zhejiang province's private account is more than 300,000 yuan, and Shenzhen's private account is 200,000 Above RMB, it belongs to the category of large cash management.
From the analysis of the content of the file, the starting point of the amount includes both a single pen and multiple accumulations, and the accumulation period should be a natural day
4. Make an appointment for cash withdrawal
Each commercial bank will establish an appointment rule, implement an appointment system for large cash withdrawals, and report relevant information to the central branch of the People's Bank of China.
5. Register for large amounts of access
The cash withdrawn and deposited by the customer above the starting amount should be registered when transacting business. Commercial banks should also report relevant information to the central branch of the People's Bank of China.
6. Cash traceability
The pilot line will consider the requirements of the People’s Bank of China’s bank account number data collection requirements and large cash monitoring requirements, and guide banking financial institutions to realize the access and business information above the starting point to be related and traceable to the cash bank account number.
To put it bluntly, for cash deposits and withdrawals above the starting point, each renminbi physical article number must be associated with access to business information, such as who took it, when it was taken, where it was taken, who deposited it, and when Where did you save it?
7. Risk prevention
For customers from high-risk industries, particularly large transaction amounts, and the frequency or amount of transactions does not match the customer's identity and daily transaction characteristics, strict verification of the authenticity and normative information of the information, or there are reasonable reasons to suspect that the customer is suspected of money laundering and other crimes In case of activity, a suspicious transaction report should be submitted, and the risk should be marked, followed up, and recorded for future reference.
For the suspicious transaction report mentioned above, please refer to the "Administrative Measures on the Report of Large-value Transaction and Suspicious Transaction of Financial Institutions" for details.
8. Cash analysis report system
Strengthen its own large cash analysis level, analyze the large cash business information reported by banking financial institutions by industry, purpose, and amount, grasp the direction of large cash flow, and predict the risk of large cash business. Under the premise of ensuring the safety of personal information and strictly regulating the use of information, exchange and share information with relevant departments.
This exchange and sharing of information with relevant departments is also relatively shocking. Some areas have seen the cooperation between the tax police and the bank in some areas. By monitoring the taxpayer's bank account, the tax department has checked it.
9. Management measures in specific areas in specific industries
1. Hebei Province focuses on the real estate industry, especially the pre-sale funds for commercial houses in Xingtai City.
2. Zhejiang Province focuses on the wholesale and retail, real estate sales, construction, and automobile sales industries, with a focus on the authenticity of the cash-out process and subsequent use.
3. Shenzhen, focusing on the management and control of operating income and expenditures using personal accounts, subdividing the sources and uses of operating income and expenditures of individual accounts, and monitoring overseas RMB cash operations.
10. Personal cash income report
Choose appropriate cities in the pilot area, and explore starting with some state organs, leaders of state-owned enterprises and institutions, and promote the information about the transaction nature and transaction amount of cash income of a certain amount or more by individual individuals.
At present, banks monitor large payments and suspicious transactions, and fulfill the obligations of reporting large transactions and suspicious transactions, and submit large transaction and suspicious transaction reports to the China Anti-Money Laundering Monitoring and Analysis Center.
The following 3 situations will be supervised!
(1) A single transfer payment of more than 1 million yuan between legal persons, other organizations, and individual industrial and commercial households (hereinafter collectively referred to as units);
(2) A single cash receipt and payment of more than 200,000 yuan, including cash deposit, cash withdrawal and cash remittance, cash draft, cash promissory note payment;
(3) Transfers of more than 200,000 yuan between individual bank settlement accounts and between individual bank settlement accounts and unit bank settlement accounts.
What is a large payment?
According to the "Administrative Measures on the Report of Large-value Transactions and Suspicious Transactions of Financial Institutions" (also referred to above (People's Bank of China Order No. 3 of 2016)) implemented on July 1, 2017, the large-value transactions are:
(1) Cash deposits, cash withdrawals, cash settlement and sale of foreign exchange, cash exchange for single or cumulative transactions of more than RMB 50,000 (including 50,000) and foreign currency equivalents of more than US$10,000 (including US$10,000) , Cash remittance, cash bill payment and other forms of cash receipts and disbursements.
(2) The transfer of non-natural person customer bank accounts and other bank accounts on the day of a single or cumulative transaction of more than 2 million yuan (including 2 million yuan) and foreign currency equivalent of more than 200,000 dollars (including 200,000 dollars).
(3) The transfer of domestic funds of natural person customer bank accounts and other bank accounts on the day of a single or cumulative transaction of more than 500,000 yuan (including 500,000 yuan) and foreign currency equivalent of more than 100,000 US dollars (including 100,000 US dollars).
(4) Cross-border transfers of natural person customer bank accounts and other bank accounts on the day of a single or cumulative transaction of more than 200,000 yuan (including 200,000 yuan) and foreign currency equivalent of more than 10,000 US dollars (including 10,000 US dollars) .
case analysis:
Recently, the Wuxi Municipal Taxation Bureau issued a notice that a company that failed to declare and pay taxes with a personal bank card constituted tax evasion and was charged back taxes and fined more than 8 million yuan! Unaccounted tax collection of personal accounts constitutes more than 5 million tax evasion and a fine of nearly 3 million!
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Things roughly go through:
The company obtained off-account sales of electric vehicles and accessories from 2017 to 2018 without tax declaration.
In 2017, I collected 12193078.7 yuan of sales proceeds through my personal account, of which 11495378.7 yuan was not recorded in the account and tax was not declared.
In 2018, RMB 27,883,309.65 was collected through personal accounts for sales, of which RMB 27,018,459.65 was unaccounted and untaxed.
After the rollover, the value-added tax will be recovered from 1670268.7 yuan in 2017 and 3839500.25 yuan in 2018. The total amount of corporate income tax collected in 2017 and 2018 was 439,662.71 yuan.
The company's act of concealing waste income and using false VAT invoices to list less revenue and more expenditures on the account book constitute tax evasion. It is planned to pay a 50% fine for the recovery of value-added tax and corporate income tax, totaling 2947.147.87 yuan.
It can be calculated that the company has been subject to tax recovery and fined more than 8 million due to the non-declaration of tax payment by the personal card collection! This is a profound lesson.