Dissertation
Dissertation > Political, legal > Legal > Chinese law > Finance Act > Tax Law

Research on Advance Pricing Agreements and Its Application in China

Author LuoZhong
Tutor ChenLiHu
School Suzhou University
Course Legal
Keywords APAs Transfer pricing International tax avoidance Multinational Associated enterprises International Tax
CLC D922.22
Type Master's thesis
Year 2004
Downloads 329
Quotes 5
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Economic globalization, the development of transnational corporations has become an important symbol of economic globalization . A large number of multinational companies use transfer pricing method of tax avoidance , the national tax authorities to take the post audit and adjustment . This method , however , difficult to choose a variety of technical indicators and determine the procedures are very complicated , heavy workload, difficult to obtain evidence , will not only increase the burden of the tax authorities , taxpayers much inconvenience , transfer pricing is one of the most complex tax issues . APA to taxpayers in advance and overseas affiliated enterprises taken by the Exchange of transfer pricing methods to report to tax authorities , the transfer pricing methods to determine compliance with the arm's length principle and accepted by the tax authorities . For the tax authorities , the pre - convention will greatly reduce the uncertainty of the tax authorities on transfer pricing adjustments ; For businesses, is conducive to enterprises operating decisions , while reducing levied for disputes , in order to avoid the interference of the tax on the economy , Advance Pricing can be an effective way for a new type of transfer pricing tax norms . Since the reform and opening up , especially after China 's accession to the WTO , multinational China 's huge market potential to attract, came to China , foreign-invested enterprises gradually increased , but many of the foreign direct investment enterprises in China claimed to be a loss , but continuous replenishment . The use of transfer pricing and foreign investors have a great relationship . The internal transaction pricing of each other multinational companies in the Group 's internal or between associated enterprises providing products , services or property used to transfer profits to overseas affiliated companies avoidance ; huge loss not only to China's tax revenue . And this will affect not know the truth of the enthusiasm of the foreign investment in China , resulting in negative effects of China's investment environment is not conducive to foreign investment in China . On the other hand , China to carry out anti - transfer pricing tax avoidance there are still many need to study and solve problems . Lack of comparable transactions , the resale price method and cost plus method , China 's laws and regulations in advance pricing level is too low, and do not have a unified national APAs program . Improve the legislative of APAs system in China , we should focus on the part of the study .

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