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Studies On The Development Trend Of The Law System For Transfer Pricing

Posted on:2006-10-03Degree:MasterType:Thesis
Country:ChinaCandidate:H Y MaFull Text:PDF
GTID:2166360155964731Subject:International Law
Abstract/Summary:PDF Full Text Request
With the continuous opening-up of China toward the outside world, especially after its entry into WTO, more and more multinationals will be coming to China for business operation as attracted by the huge potential market here. These foreign investment enterprises ("FIE"), on one hand, bring in advanced management experience, personnel and technology and makes up for the inadequate home investment capital; on the other hand, some FIEs aiming at the maximum profitability and the minimum tax burden, would seek for various illegal interests in an open way of TP. The author selected < studies on the development trend of tax system for TP> as subject of the thesis to conduct a systematic and in-depth study on international tax avoidance and TP, as well as the intruduction and analysis of TP in various countries and the principles of OECD by borrowing the successful experience abroad and combining the actual situation in china.Made up of Introduction and four chapters.In introduction, the author elaborates the reason for subject selection, the theoretical and realistic meaning of the subject.Chapter One. To lay a solid foundation for the whole thesis, a complete and in-depth elaboration is conducted over the basic theories of international tax avoidance and the fact how the multinationals would avoid tax internationally by means of TP, etc.Chapter Two To lay a solid foundation for the basic theoretical system for the tax system for TP, exploration and discussions are carried out on the basic theories of tax system for TP, such as its connotation, establishment and development; the definition of its main body - associated enterprises, its basic principles and TP.Chapter Three. Have explained the development trend of the law system for TP and emphatically elaboration on a new prior adjustment system adopted to solve the problems concerning the tax system for TP among the multinational associatedcompanies - Advanced Pricing Agreement. To better realize this new system in practicing the tax system for TP, a detailed description is made in this chapter regarding the origin and development of APA, its basic theory and the specific practice procedures.Chapter Four. Analysis on Current Situation The establishment of tax system for TP in China has just started and is at the stage of exploration. Though there is already some legislation on the tax system for TP, problems still exist. In this chapter, elaboration is conducted over the tax avoidance of the FIEs in China by means of TP, meanwhile an in-depth analysis is made on the various problems existing in the tax system for TP in China and the idea is put forward that in a view to prevent the multinationals from avoiding tax by TP, the relevant tax system should be set up and completed.
Keywords/Search Tags:multinational, companies, international tax avoidance, transfer pricing(TP), advance pricing arrangements(APA)
PDF Full Text Request
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