Chinese Advance Pricing Arrangements System Consummation

Transfer Pricing is a most concerned issue in the nowadays international tax revenue. The traditional Transfer Pricing system uses afterwards audits and the adjustment method, the existence of which is difficult to be overcome,Advance Pricing Agreement then arises at the historic moment. Advance PricingAgreement causes the Transfer Pricing government supervising and managing to be engaged in the after-event adjustment model to transform into the advance protocol model, which avoids the intrinsic limitation of the after-event adjustment model and validly reduces the transaction cost in the process of levy, and enhances the reasonable anticipation of the transnational taxpayers for their commercial activity and guarantees the transaction security well.Based on all sorts of merits of Advance Pricing Agreement, more than 30 countries all have implemented the Advance Pricing Agreement system one after another since the US government carried out the Advance Pricing Agreement in 1991. The Advance Pricing Agreement of our country was executed later, it has a low legislation level and imperfect system, and lacks the limited information origin and the valid management method; the more unilateral protocols was signed in practice, which cannot avoid the dual taxation validly.