The Rerearch On Advance Pricing Arrangement

As the world economy developing constantly expanding cross-border transactions, the resulting transfer pricing related transactions prevalent in every country, because transfer pricing are likely to damage the tax benefit of a country ,so national tax authorities hope to find a way out an effective mechanism for the problem, but a long time to a variety of solutions have some defects. A more effective way to find solutions, to the United States led the world's national tax administration authorities have tried new management of the system, and last century, from 80 to 90 age that a new System - Reservation system (Advance Pricing Arrangement), also known as the APA. APA system, the emergence of cause transfer pricing of revenue management model by the retroactive adjustment of regulation into conform in advance, this change full reflects the both tax collectors and taxpayers and to average benefit from beginning, is the transfer pricing tax system inevitable trend and results. APA system sought through the establishment of a series of enterprises by tax accepted by both sides of the pre-determined criteria, between countries, international taxpayers and tax administration have reached full agreement between the authorities in order to reduce tradition transfer pricing tax administration costs, and solve the side on the issue of transfer pricing disputes and conflicts, can promote the cross-compliance of taxpayers, increase tax revenue, and enhance the efficiency of tax administration of transfer pricing and quality. Advance Pricing ultimate goal is to strengthen the management of a country's anti-tax avoidance and safeguard national sovereignty, to avoid international double taxation.As the transfer pricing system in China started late, compared to developed countries, at the present stage of advance pricing system in China has both theoretical and practical importance. In theory, although the Transfer Pricing Tax System has won a number of important results obtained, but the Advance Pricing Theory is not enough basic research and summarize existing theory to guide APA tax practice of transfer pricing in China is still inadequate. In practice, China has signed on the APA and supervision when there is still much to be desired, the need to study and learn through experience and practice in developed countries to amend and supplement the inadequate tax system in China advance pricing. In this paper, the Western economic principles such as taxation and tax compliance on the theory of the classical theory as the main platform to learn from foreign advanced pricing system in theory and practical experience, on the Advance Pricing analysis and comparison of the current situation, of Advance Pricing System in China's development and improved.Consisted of four parts: Part I introduces the APA system, the meaning of APA and the APA to the background in all aspects of basic theory. The second part introduces the APA regime in the national production and development process, including the countries of the world and our APA origin and development, while the system in accordance with national development of APA compared to draw upon the development of virtues APA. Part III introduces the development of China's APA, and APA development in China's latest achievements, but also introduced the practice of our APA - On the sign, monitoring and enforcement. The fourth part is more advanced in the advance pricing system and pricing of our current reservation system, points out the lack of current APA system. The fifth part mainly based on Advance Pricing the problems, international experience, on the Advance Pricing System in China to make a few suggestions. Advance Pricing System in China and explore the application is still in its initial stages, it is necessary to further research and extension, Advance Pricing System.