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Studies On The Law System Of Advance Pricing Arrangement

Posted on:2007-05-22Degree:MasterType:Thesis
Country:ChinaCandidate:Y GuoFull Text:PDF
GTID:2166360182977520Subject:International Law
Abstract/Summary:PDF Full Text Request
With the world economy development is toward a unified direction tendency, the international trade is looking up. More and more multinationals will be coming to China for business operation as attracted by the huge potential market here. These foreign investment enterprises bring in advanced management experience, technology and investment capital, some foreign investment enterprises aiming at the maximum profitability and the minimum tax burden, would seek for various illegal interests in an open way of transfer pricing(TP).Tax authorities deals with TP with many different methods, but traditional transfer pricing methodology exposes a lot of disadvantages. Advance pricing arrangement (APA) is a new method to deal with TP, it exposes unsubstituted advantages. The author selected Studies on the Law System of Advance Pricing Arrangement as subject of the thesis to conduct a systematic and in-depth study on associated corporations and TP , as well as the introduction and analysis of APA 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 associated corporations and TP, such as its connotation, establishment and development.Chapter Two .To lay a solid foundation for the basic theoretical system for APA, exploration and discussions are carried out on the basic theories of APA. To better realize this new system in practicing, a detailed description is made in this chapter regarding the origin and development of APA, its basic theory and the specific practice procedures.Chapter Three. Have explained the development trend of the law system for APA abroad, a complete and in-depth study on characters and sutras of the law system for APA abroad.Chapter Four. Analysis on Current Situation. The establishment of law system forAPA in China has just started and is at the stage of exploration. Problems of the law system for APA exist. In this chapter, an in-depth analysis is made on the various problems existing in the law system for APA in China and the relevant law system should be set up and completed.
Keywords/Search Tags:Associated Corporations, Transfer Pricing(TP), Advance Pricing Arrangement(APA)
PDF Full Text Request
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