Studies On The Company's Advanced Pricing Arrangement Decision

Now revenues are still taking post-modification mode on transfer pricing issue. In this mode, taxpayers will have a high cost to cope with the revenues'survey. For taxpayers ,this mode not only increased the working cost but also increased the uncertainty in working, going against planning scientifically in management. How to reduce this effect have become the problem on which the taxpayers focus increasely.The appearance of the Advanced Pricing Agreement (APA) provides a new opportunity for corporation to solve the transfer pricing problem. Carrying out APA need some conditions, it is affected by the environment inside and outside of the company. So this text firstly analyse the factors that affect the APA from the aspect of the inside and outside of the company. In the company ,the factors that affect the APA are transfer pricing ,the survey of the revenues ,double taxation and the system of the company's decision-making. Outside of the company ,the factors that affect the APA are policy environment, industry status, tax jurisdiction and tax agreement. This text think all the factors we talked above are the primary factors that affect the implement of the APA, and analyses how these factors acted and how to avoid or utilized. Later, the text examine the mechanism in using APA as a management tool, and established foundation on using APA. This text consider the APA is the result of the game between the revenues and taxpayers, and is also another implement of the indenture theory. It find the production of the APA have inevitability, the feature of the APA decide it can be a tool in company management involved tax. These theory studies base the implement of APA for company. On these theories ,the text analyse the flow of constitute transfer pricing, and analyse the examples of the tangible assets'purchase and sale, intangible assets'purchase and sale and offer work, It analyse how to choose the method of the transfer pricing, do comparable analysis and decide critical assumption in every trade style. Relating the theory study with practice more closely. APA is not perfect, and company's decision-making also isn't perfect, this may bring some trouble into the advanced pricing arrangement. So in the end of this text, it explains the domino effect of the APA, the venture in decision-making and how to avoid venture in order to make the study become integrity and preciseness.On the base of the using many learners'fruits ,this text analyse problem from the visual angle of company management, and encircled the advance pricing agreement, according to the decision-making process to research, bring forward a systemic method to settle the critical problem in advanced pricing arrangement. Researching the APA from managing aspect not only can improve the science and feasibility of the APA decision-making but also can promote the perfect of the APA.