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Research on the Advance Pricing Arrangements

Author: KongLin
Tutor: RongJianHua
School: Tianjin University of Finance and Economics
Course: Economic Law
Keywords: APAs Transfer pricing Transfer pricing methods Key assumptions
CLC: D912.2;F812.42
Type: Master's thesis
Year: 2011
Downloads: 127
Quote: 1
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Abstract


With the accelerating process of world economic integration, trading activities between the enterprise and its associated enterprises has been rapid development, the taxpayer's tax havens have become increasingly prominent. In this regard, the vast majority of countries are specially formulated transfer pricing system to the regulation of this behavior. Traditional transfer pricing adjustment after the adjustment, this adjustment has a high cost, low efficiency, the difficulties of proof and other defects. It is in this context, APAs making a previously recognized system for resolving transfer pricing issues emerged. Nearly 20 years of practice development proved, The APAs tax solve the traditional problems of transfer pricing can play a positive role. APAs tax system, the emphasis is cooperation between the relevant main advocate the use of a non-confrontational way to resolve tax conflicts between countries. Parties through consultations and even compromise to reach an agreement in order to achieve long-term win-win situation between both sides., Which apparently has the double meaning of the theory and practice. At present, many countries have established and implemented a APAs tax system, the United States, Japan is the introduction of APAs tax system's earliest and most developed countries, representing the forefront of the development of advance pricing tax system. APAs in the rapid development of the countries in the world caused the attention of the Economic Cooperation and Development (OECD), the specially formulated \Due to the late introduction of APAs in China tax system, there is a great lack of experience in practice, there is great room for improvement in the legislation. Future APAs tax system in our country can be further developed, should constantly explore theoretical and practical aspects on the basis of, and actively learn from the advanced experience of the United States, Japan, OECD in APAs regulation of accumulated. Refinement in the legislative provisions on the confidentiality of information, the key assumptions, transfer pricing methods to enhance the operability of the APAs. Improve the level of tax collection in practice, the establishment of the APA to centralized management model; encourage the conclusion of double (multiple) edge APA; Supplementary Provisions to the taxpayer's burden of proof, to expand the sources of information, the establishment of a unified, shared information database. I believe that will continue to improve, the APA to continue to accumulate experience and learn from the practice and theory of foreign.

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CLC: > Economic > Fiscal, monetary > Finance, the state's financial > China's financial > Financial income and expenditure > Tax
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