Advance Pricing Theory And Practice

Multinational company has been the important symbol of economic globalization.They usually avoid tax by means of Transfer Pricing.At present In many countries tax bureau mainly depends on afterwards auditing and adjustment.But by these means it is difficult to make sure of many kinds of technical targets and to get accurate messages.There are much work to do,and complicated procedure not only increased the debts of tax bureau also made taxpayer bother. Transfer Pricing is one of the most complicated tax problems.Advanced Pricing Tax System (APTS) is a new administrative system of international transfer pricing emerging in international taxation recently.As a way to administer transfer pricing in multinational company and eliminate the effect of transfer pricing on international taxation,APTS has been widely used in western developed countries such as USA,Japan,European countries,etc and some developing countries and regions,and is becoming a trend for the development of transfer pricing tax system.After the reform and opening-up,the integration process of international economy is accelerating.Especially after we entried into WTO,our national economy has integrated with world economy.The top 500 enterprises came to China to invest and set up factories one after another,and tax rights and interests problem caused by transfer pricing in multinational enterprises emerges and became increasingly urgent,followed by unavoidable tax coordination and disputes between nations.Therefore it is of practical significance to study on and improve our APTS,for the perfect of our transfer pricing tax system,the consummation of our tax administration environment,the improvement of international investment environment and the promotion of our international communication and cooperation.APTS researching belongs to tax practice of international tax management.Thethesis tries to do some mechanism and comprephensive research and analysis on thebasis,body,principles and law base of tax theory of APTS.Then using the foreign successful experience for reference,combined with our national state anddevelopment,it provided views and suggestions about how to perect APTS in ourcountry,hoping to contribute to the consumption of the transfer pricing taxadministration in our country by analyzing a one-side case of APTS.The article is divided into four parts:The first part: the related theories of APTSIt introduces and analyzes the introduction and development,the definition,body,basicdiscipline,basis of theory and lawing gist of APTS;The second part: the international comparison of APTS practiceThroughout the analyzing comparison to the effective dealings of APTS in USA andOECD,this part summarises any useful indication and example to the practice ofAPTS in our country;The third part: the practice of APTS in our countryOn the basis of analyzing the important meanings and helpful situation to push APTSin our country,this part analyzes some problems that has been existing in the practiceof APTS in our country and makes some relative suggestions to pecfect the APTS inour country;The fourth part: appendixIt is the analysis the case of SYDJ co., ltd.