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The Analysis Of Legal Theory Of Our Country's Transfer-Pricing Tax System

Posted on:2007-08-18Degree:MasterType:Thesis
Country:ChinaCandidate:L ZouFull Text:PDF
GTID:2166360185965528Subject:Economic Law
Abstract/Summary:PDF Full Text Request
With the globalization of economic activities and the rapid development of market economy , more and more multinational compnies have entered China to invest . On one hand , they brought in advanced management experience , talented pepole and technology;on the other hand , in order to pursuit maximum profits, they manipulate transfer pricing ,and in some degree they evade paying taxes which not only seviously damage our country's tax income but also cause unequal tax paying among companies. It does harm to the principle of equally distribute international tax and equally paying tax, it also damage our country's economic environment ,make it hard for the reuse of foreign capital. The transfer pricing tax system of China have just begun ,and it has many faulty. In order to maintain national benefit and secure our tax system ,research over China's transfer pricing tax system as well as doing rational discuss and practical analysis will be helpful for us to understand the behaviour of evade taxes , rise our ability to prevent such behaviour ,and gradually perfect relative law .Only in doing this can we prevent such evade taxes behaviour done by multinations and therefore carry on a law control.This is one of a most important tasks in the development of our tax system.This artical based on some true cases from both abroad and home illuminates the influence that multination's transfer pricing behaviour has on our country's economy. Analise the motivation of this system, including tax motivation and non-tax one .This discussion of the legal theory of transfer pricing tax system is based on the principle of equal tax , It also discuss the criterias of many other country's related enterprises. Examine, evaluate the principles of current transfer pricing law control, including total profit principle, Arm's length principle,comparable principle,,as well as the solution provided by foreign country's related enterprises,such as comparable uncontrollable pricing method;Resale pricing method;Cost-plus method ,and analise their advantages and disadvatages .It compares the transfer pricing tax system amoung development countries ,and therefore putforword the related problem of China and provide solutions.
Keywords/Search Tags:transfer-Pricing tax system, related enterprises, Arm's length principle, Advance Pricing Agreement
PDF Full Text Request
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