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Research On The Advance Pricing Arrangement In The International Tax Law

Posted on:2019-10-07Degree:MasterType:Thesis
Country:ChinaCandidate:X Y WenFull Text:PDF
GTID:2416330575472222Subject:International Law
Abstract/Summary:PDF Full Text Request
The tax system of APA began in Japan and has been adopted by most countries in the world.The Organization for Economic Cooperation and Development also showed great concern with this tax system.With the introduction of the "Auxiliary Pricing Guide under the Mutual Negotiation Process," this tax system has been fully developed in both the foreign-related and international coordination rules.As the forefront of today's era,the tax system of APA has extremely strong vitality in the two most important goals of the international tax law—avoiding double taxation and anti-avoidance cooperation.From the perspective of the tax authorities,the APA is conducive to reducing the pressure of the tax authorities after the post audit;from the perspective of the multinational corporation,it is conducive to reducing the uncertainty in the process of production and operation;from the perspective of the nation,it is beneficial to reduce the impact between the tax authorities and the taxpayers.It will promote the establishment of the service type government.In addition,the double(multiple)edge of the APA is conducive to the realization of tax cooperation between countries and avoids the phenomenon of double taxation.With the Belt and Road initiative's promotion and implementation,international economic exchanges have become increasingly prosperous,improve the APA will help to promote the benign development of international trade and investment and promote the construction of a new order of international economic.Since the reform and opening,China has been actively exploring and advancing in taxation and a series of laws and regulations have been enacted,which has created a good economic environment for our country and other countries in international investment and trade.As far as the APA is concerned,China has made a provision in the enterprise income tax law for the first time in 2007,and then issued a special tax adjustment implementation method in 2009.This problem has been refined though that method,but it should say,compared with other tax systems,the tax system of APA is still a new thing in our country,and the above regulations are still necessary to be consummated.This article focuses on theory and practice,and gives attention to both at home and abroad.Based on the analysis of the general theory of APA,using a case is as a clue for scenario assessment,and from the standpoints of international coordination rules and foreign-related rules,the article explains the theory and practice of the tax system of APA and provides suggestions for China to deal with this issue.
Keywords/Search Tags:The tax system of Advance Pricing Arrangement, International Double Taxation, Anti-Tax Avoidance, Transfer Pricing
PDF Full Text Request
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