预约定价安排的全球实践及其在中国的快速发展

Global Practice of APA and Its Rapid Development in China

本文认为,随着转让定价方法的不断创新和近期各国持续加强对税基的保护力度,税企双方就转让定价问题的争议越来越多,而且往往涉税金额巨大,税务审计还会给企业以后年度的运营带来极大的不确定性,因而税企双方都在寻求一种避免或解决争端的有效手段。在这种情况下,预约定价安排的独特功能优势使其在全球范围内得到快速发展并趋于程序简化。近年来,中国国家税务总局连续颁布《中国预约定价安排年度报告》,本文对该报告进行了解读,并对其中体现出的中国预约定价制度的最新发展进行了分析。

This paper argues that, with the continuous innovation of Transfer Pricing methods and the enhancing endeavor of tax base protection by different countries at present, controversies about Transfer Pricing, which always involve a large amount of money, between enterprises and tax authorities become more and more intense, and tax audit will expose enterprises to great uncertainties thereafter years. Thus, tax authorities and enterprises are both trying to fine one effective method to solve this issue. In such a situation, thanks to its special functional advantages, the Advance Pricing Arrangement gains a rapid development globally and its procedures tend to be more and more simplified. In recent years, the State Administration of Taxation in China has annually issued the China Advance Pricing Arrangement Annual Report. This paper gives an interpretation of the latest Report, and analyzes the development trend of APA in China in the future according to the content of the Report.