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针对跨国纳税人利用国际避税地进行避税,各国政府采取了种种反避税措施,例如加强对转让价格的管制,这是一项重要的反避税措施。不少国家采取了对任意确定转让价格的限制措施。如采用局外价格监督和管理转让价格。如果按局外价格计算发现由于价格不当而发生额外利润,则应按局外价格来调整应税所得额,提高了应税所得额也就是提高了纳税额。这
In view of multinational taxpayers using international tax havens for tax avoidance, governments have taken various anti-avoidance measures, such as strengthening the control of transfer prices, which is an important anti-avoidance measure. Many countries have adopted restrictions on arbitrarily determining the transfer price. Such as the use of outside prices to monitor and manage the transfer price. If it is found by external price calculation that extra profit occurs due to improper price, the taxable income should be adjusted according to the external price, the taxable income should be raised, and the tax payable should be raised. This