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Research On Advance Pricing Arrangement And Related Issues

Posted on:2007-02-23Degree:MasterType:Thesis
Country:ChinaCandidate:F XuFull Text:PDF
GTID:2166360212978229Subject:International Law
Abstract/Summary:PDF Full Text Request
The development of multinational companies has become an important symbol of economic globalization, along with which transfer pricing has greatly increased the tax bureaus'burden. Because of the universality of transfer pricing and the disadvantages of traditional transfer pricing methodologies, advance pricing arrangement is welcomed by both tax bureaus and taxpayers. China has made advance pricing arrangement since 1998, but the lack of experience, personnel and rules has blocked the development of advance pricing practice. This article wants to make some contribution to the development of advance pricing arrangement of China.Besides the introduction and conclusion, the thesis includes 4 chapters.Chapter 1 defines advance pricing arrangement, analyzes the basis of advance pricing arrangement and the nature of advance pricing agreement, and points out the advantages and disadvantages of this system.Chapter 2 does research on advance pricing arrangement in the USA and OECD, introduces the advance pricing practice in developed countries, and summarizes the tendence of advance pricing arrangement.Chapter 3 mainly researches the difficulties in advance pricing practice, including the rollback of TPM, advance pricing arrangement for small business taxpayers, the confidentiality of taxpayers'information, and revising, canceling and revoking the advance pricing agreement, and makes suggestions according to the situation of China.Chapter 4 introduces the development of advance pricing arrangement in China, points out the deficiencies of the rules and makes some suggestions for revising.
Keywords/Search Tags:Advance Pricing Arrangement, Transfer Pricing Methodology, Mutual Agreement Procedure
PDF Full Text Request
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