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由于经济的全球化及跨国联属企业经营行为的自由化,各国对转让定价进行调整的各种方法在实践中,已暴露出许多弊端。为找到一种征纳双方都能接受的调整方法以协调税务当局与纳税人之间的关系,APA便应运而生。预约定价制度(简称APA,advance pricingagreement)是20世纪90年代初国际上为解决转让定价税收管理而积极推行的一种管理制度,被西方各国广泛运用,现已形成一套较完善的操作规程。在我国,APA仍属新事物,缺乏较成熟的经验和规范性操作。
Due to the globalization of economy and the liberalization of business activities of transnational affiliates, various countries have adjusted their transfer pricing methods in practice, and many disadvantages have been exposed. The APA came into being to find a way to accommodate both parties to adjust the tax authorities and taxpayers. Advance pricing agreement (APA) is an international management system that was actively implemented in the early 1990s to solve the problem of transfer pricing tax administration. It has been widely used by all countries in the West and has now formed a relatively complete set of operating procedures. In our country, APA is still a new thing, lack of more mature experience and normative operation.