Research On Evaluation Index System Of Advance Pricing Agreements

With the rapid speed of the world economy globalization, multinational companiesand its pricing affairs become the hot point of the international tax authorizations.Driven by the maximization of the whole profit, the multinational companies do theirbest to perfect the allocation of the resources all over the world. However, along withthe transferred of the resources are the interests of companies, and the tax revenue ofrelevant countries. If multinationa company excessively takes care of its own benefitsand overlooks the importance of banlancing the related interests subjects, its tranferpricing affairs will be monitored so carefully by all the tax authorizations.Due to thereasons above, on one hand it will increase the hard burden to corporation and cause taxinefficiency.In order to solve the problem of transfer pricing,the global tax authorizations madetheir efforts to find out a new pricing system: Advanced pricing agreements(APAs).Based on the transfer pricing,the new system improves on the precondition andreajustment parts. An advance pricing arrangement for multinational companies canreduce tax risk and strengthen international coorperation. But APA need closecooperation between company and tax authority, highly coordination of interestsegmentation, these undoubtedly increased the difficulty of APA. In a word , theadvantages and disadvantaged of APAs coexist.In the first chapter.does this essay ananlyze the significant importance of APA.Then it combined the analysis of theories and practical experiences to understand thecontent and process of APA thoroughly. On one hand, it researches on the transferpricing to find out the differences between APA and TP. On the other hand, it alsodivides dozens of factors into two categories.In the third charpter, 12 factors areanalyzed logically and instructed into a network relationship mode. In the fourth chapter,based on the mode is the evaluation system APA evaluation index system constructed.To make sure evaluation the system reasonanle and could be applied to practicalproblems, this study use ANP method to review index system. After that,this essay takeadvantae of ANP software to simplify the calculation process. Finally, we make use ofA company's materials to verify the conclusions scientific and rational.