Research On Advance Pricing System

APA system is a taxable entity and the tax authorities on the future of economic matters how taxes are pre-agreed arrangements for the new system. In the long-term study of the APA system, mostly focusing on its practical value, from the perspective of legal theory to analyze the few studies of the meaning of APA. Based on existing research, more emphasis on theoretical research, analysis from the perspective of law APA essence, both characterized by civil law, administrative law, contract law, tax law, international treaties, agreements and other branches of law; learn civil law and tax law and other branches of law relevant ideas,suggestions rationalization.This paper is divided into six sections: Introduction, APA system and its legal basis generated feature APA legal system analysis, development of reservation status quo pricing and problems in other countries(regions) APA legal system and to China The revelation,improve the legal system of advance pricing tax advice.The introduction describes the major research appointment of theory and practical significance pricing system, this paper introduces the main basis of the method. "APA regime and its objective basis resulting" analyzes several definitions of APAs currently exist in our academic and define its meaning; also introduced the legal basis for APA Institution. "Legal Characteristics APA system analysis" describes the presence of APA Tax system, economic law, administrative law, civil law, philosophy and law characteristics Law Contract Law, also introduced a multi-sectoral legal implications which brought the system to APA positive impact. "Our pricing reservation status quo and problems of development," combing the country APA system development process, current situation and speak from the perspective of law, there is a shortage and what needs improvement, these deficiencies caused real problems. "Other countries(regions) APA legal system and Enlightenment" This section describes the APA US and China's Hong Kong tax system, refining the APA to bring our tax system in the United States mainland and Hong Kong revelation. "Improvement of the reservation proposal pricing Tax Law," the final part of the article concluded, before the text analysis of the APA's inadequate as the basis for drawing inspiration from other countries on China APA system and law enforcement from the legislative point of view angle to make reasonable suggestions.