The transfer of the rural collective construction land is increasingly accelerating,and the factors affecting transfer price are manifold. In this paper,the research area is Yichang,and we establish hedonic price mode...The transfer of the rural collective construction land is increasingly accelerating,and the factors affecting transfer price are manifold. In this paper,the research area is Yichang,and we establish hedonic price model to explore and analyze the factors which affect the collective construction land transfer price. The simulation results show that in geographical factors,the higher degree of prosperity,road accessibility and soundness of infrastructure will result in higher collective construction land transfer price; in economic factors,the higher farmers' per capita net income and added value of the village's tertiary industry will lead to higher collective construction land transfer price; in ownership factors,the integrity of usufruct,disposition and possession has increasingly significant impact on collective construction land transfer price. In the process of establishing rural collective construction land circulation market,the government should gradually improve conditions of collective construction land; strengthen the construction of the rural economy,improve the economic attribute of the collective construction land; establish and improve China's rural collective construction land-related laws and regulations,make the rural collective construction land use rights clear,and give the whole rights of occupation,use,earning and disposition.展开更多
Agricultural land is the key to large-scale agricultural management,and the transfer price is the key to the success or failure of land transfer. At present,there are many problems in the pricing of rural land transfe...Agricultural land is the key to large-scale agricultural management,and the transfer price is the key to the success or failure of land transfer. At present,there are many problems in the pricing of rural land transfer in China,such as low price,random pricing,and large price difference,which seriously hinder the development of rural land transfer. Drawing lessons from the research results of domestic and foreign scholars,combined with the actual situation of rural land transfer in China,this paper analyzes the influencing factors of land transfer price in the context of rural land reform. Finally,according to the influence of different factors on the behavior of agricultural land transfer,this paper proposes establishing and perfecting the evaluation system of contracted land,perfecting the evaluation institution of transferred land assets and establishing a unified dynamic monitoring system of land transfer price in the whole country,and then driving the broad masses of farmers to get rich together,which is of great significance to achieving the revitalization of China’s rural areas.展开更多
The factors influencing the water supply price of a hydraulic project include natural conditions and economic policies. This paper thoroughly demonstrates the water price of South-to-North Water Transfer Project from ...The factors influencing the water supply price of a hydraulic project include natural conditions and economic policies. This paper thoroughly demonstrates the water price of South-to-North Water Transfer Project from the viewpoint of economic policies. It is considered that if the project is assigned as a profitable one and built depending on commercial loan from bank completely or mostly, the water price will be too high to be undertaken by users,and if the project places the public good at first while considering the economic benefit, its investment mainly relies on the state (national or local governments) appropriation and self-raised funds and a little from the bank loan on favorable terms, the price determined according to the principle of satisfying the cost and reasonable profit will be relatively lower and can be undertaken by the users in the North China where water shortage is serious. The problem of higher water price of agricultural irrigation to the north of the Yellow River can be tackled by taking measures such as "compensating agriculture by industry" according to foreign practical experiences and relevant suggestions.展开更多
The increase of inter-boundary transactions brings a number of benefits for enterprises. However, even when benefits of transfer pricing are evident, multinational organizations still face legal challenges, including ...The increase of inter-boundary transactions brings a number of benefits for enterprises. However, even when benefits of transfer pricing are evident, multinational organizations still face legal challenges, including performing parts of transactions in another jurisdiction and motives of tax officials in investigating transfer pricing. This is especially true when countries do not want to lose benefits from tax collection. Therefore, many countries and organizations such as the Organization for Economic Cooperation and Development （OECD）, Pacific Association of Tax Administrators （PATA）, the European Union （EU）, and Vietnam have introduced requirements for transfer pricing documentation to prevent transfer pricing manipulation and maintain benefits from taxes. The aim of this research was to assess the compliance of those requirements of foreign direct investment （FDI） enterprises in Vietnam. This article which is a summary of our research includes the following sections： （1） OECD guidelines of transfer pricing documentation; （2） Vietnam regulations of transfer pricing documentation; （3） results of the research; and （4） discussion and conclusion.展开更多
The Japanese Taxation Agency （JTA） introduced transfer pricing taxation （TPT） in order to suppress the outflow of profits and therefore taxes of Japanese companies, which are expanding overseas. There have been ma...The Japanese Taxation Agency （JTA） introduced transfer pricing taxation （TPT） in order to suppress the outflow of profits and therefore taxes of Japanese companies, which are expanding overseas. There have been many press reports regarding the application of TPT, and so there is much public attention on this issue. TPT is applied to unnatural transfer prices （TP）. If TPT is applied to a multinational company （MNC）, the company will need to bear enormous documentation costs in its calculation of the ratable price. In addition, in the last few years, the target of TPT is shifting to the overseas transfer of intangible assets, such as trademarks, royalties, patents, and charges income. As a result, companies have become more careful about TPT and investors tend to pay attention to companies＇ TPT strategy. With regard to this point, this paper examines how the market evaluates news regarding TP by investigating the market reaction to an initial press report mentioning that a firm was involved in a TP manipulation and may be guilty of tax underpayment. We examine these events both because press reports are currently under intense scrutiny and because there has been very little research on firms that engage in tax sheltering （see, e.g., Graham ＆ Tucker, 2006; Hanlon ＆ Slemrod, 2009）. Some view the fact that not all firms engage in tax sheltering as surprising because of the widespread view that shelters, at least in the 1990s, in expectation, offered a positive net present value position. The potential negative public relations effect is often cited as one reason for this ＂under-sheltering＂ phenomenon （Bankman, 2004）. On the event study analysis, we find that the Japanese capital market has shown a statistically significant negative reaction to the press reports. This result is due to a strong distrust of corporate activity regarding TP strategies. Moreover, in order to clarify the reason why the market responds to reports of TPT being applied, we compute the cumulative abnormal returns （CARs） around the date of the press report and conduct two-stage least-squares estimation to examine where this result regarding the market reaction comes from. Our results indicate that the variables for intangible assets and effective tax rate and the variables which represent the extent of corporate governance （CG） are statistically significant with respect to these reactions.展开更多
A goal of transfer pricing may be to maximize after tax revenue by setting transfer prices that reduce the total tax paid. ＂Transfer pricing＂ is the pricing of products or services provided by one division to other ...A goal of transfer pricing may be to maximize after tax revenue by setting transfer prices that reduce the total tax paid. ＂Transfer pricing＂ is the pricing of products or services provided by one division to other division of the same corporate entity. Most of the corporate entities are using the method of ＂Window dressing＂, which is a technique used in preparation of financial statements of corporate entities. A transnational corporation is any enterprise that undertakes Foreign Direct Investment （FDI）, owns or controls income gathering assets in more than one country, produces goods or services outsides its country of origin, or engages in international production. Profitability of the transnational corporate entities is being manipulated by the technique of transfer pricing. Abuse of transfer prices is a key tool used by the corporate entities to think that they have virtually no profit; hence, they shouldn＇t pay any taxes. India needs to realize the fundamental need for co-operation among tax administrations in order to remove the obstacles that international double taxation presents to the free movement of goods, services and capital between various countries. In this context, one needs to consider that transactions among associated enterprises may take place under different conditions from those taking place among independent enterprises, while enforcing the act of transfer price mechanism. This paper focuses on transfer pricing and its implications in transnational transactions.展开更多
基金Supported by National Social Science Foundation(12CGL092)
文摘The transfer of the rural collective construction land is increasingly accelerating,and the factors affecting transfer price are manifold. In this paper,the research area is Yichang,and we establish hedonic price model to explore and analyze the factors which affect the collective construction land transfer price. The simulation results show that in geographical factors,the higher degree of prosperity,road accessibility and soundness of infrastructure will result in higher collective construction land transfer price; in economic factors,the higher farmers' per capita net income and added value of the village's tertiary industry will lead to higher collective construction land transfer price; in ownership factors,the integrity of usufruct,disposition and possession has increasingly significant impact on collective construction land transfer price. In the process of establishing rural collective construction land circulation market,the government should gradually improve conditions of collective construction land; strengthen the construction of the rural economy,improve the economic attribute of the collective construction land; establish and improve China's rural collective construction land-related laws and regulations,make the rural collective construction land use rights clear,and give the whole rights of occupation,use,earning and disposition.
文摘Agricultural land is the key to large-scale agricultural management,and the transfer price is the key to the success or failure of land transfer. At present,there are many problems in the pricing of rural land transfer in China,such as low price,random pricing,and large price difference,which seriously hinder the development of rural land transfer. Drawing lessons from the research results of domestic and foreign scholars,combined with the actual situation of rural land transfer in China,this paper analyzes the influencing factors of land transfer price in the context of rural land reform. Finally,according to the influence of different factors on the behavior of agricultural land transfer,this paper proposes establishing and perfecting the evaluation system of contracted land,perfecting the evaluation institution of transferred land assets and establishing a unified dynamic monitoring system of land transfer price in the whole country,and then driving the broad masses of farmers to get rich together,which is of great significance to achieving the revitalization of China’s rural areas.
文摘The factors influencing the water supply price of a hydraulic project include natural conditions and economic policies. This paper thoroughly demonstrates the water price of South-to-North Water Transfer Project from the viewpoint of economic policies. It is considered that if the project is assigned as a profitable one and built depending on commercial loan from bank completely or mostly, the water price will be too high to be undertaken by users,and if the project places the public good at first while considering the economic benefit, its investment mainly relies on the state (national or local governments) appropriation and self-raised funds and a little from the bank loan on favorable terms, the price determined according to the principle of satisfying the cost and reasonable profit will be relatively lower and can be undertaken by the users in the North China where water shortage is serious. The problem of higher water price of agricultural irrigation to the north of the Yellow River can be tackled by taking measures such as "compensating agriculture by industry" according to foreign practical experiences and relevant suggestions.
文摘The increase of inter-boundary transactions brings a number of benefits for enterprises. However, even when benefits of transfer pricing are evident, multinational organizations still face legal challenges, including performing parts of transactions in another jurisdiction and motives of tax officials in investigating transfer pricing. This is especially true when countries do not want to lose benefits from tax collection. Therefore, many countries and organizations such as the Organization for Economic Cooperation and Development （OECD）, Pacific Association of Tax Administrators （PATA）, the European Union （EU）, and Vietnam have introduced requirements for transfer pricing documentation to prevent transfer pricing manipulation and maintain benefits from taxes. The aim of this research was to assess the compliance of those requirements of foreign direct investment （FDI） enterprises in Vietnam. This article which is a summary of our research includes the following sections： （1） OECD guidelines of transfer pricing documentation; （2） Vietnam regulations of transfer pricing documentation; （3） results of the research; and （4） discussion and conclusion.
文摘The Japanese Taxation Agency （JTA） introduced transfer pricing taxation （TPT） in order to suppress the outflow of profits and therefore taxes of Japanese companies, which are expanding overseas. There have been many press reports regarding the application of TPT, and so there is much public attention on this issue. TPT is applied to unnatural transfer prices （TP）. If TPT is applied to a multinational company （MNC）, the company will need to bear enormous documentation costs in its calculation of the ratable price. In addition, in the last few years, the target of TPT is shifting to the overseas transfer of intangible assets, such as trademarks, royalties, patents, and charges income. As a result, companies have become more careful about TPT and investors tend to pay attention to companies＇ TPT strategy. With regard to this point, this paper examines how the market evaluates news regarding TP by investigating the market reaction to an initial press report mentioning that a firm was involved in a TP manipulation and may be guilty of tax underpayment. We examine these events both because press reports are currently under intense scrutiny and because there has been very little research on firms that engage in tax sheltering （see, e.g., Graham ＆ Tucker, 2006; Hanlon ＆ Slemrod, 2009）. Some view the fact that not all firms engage in tax sheltering as surprising because of the widespread view that shelters, at least in the 1990s, in expectation, offered a positive net present value position. The potential negative public relations effect is often cited as one reason for this ＂under-sheltering＂ phenomenon （Bankman, 2004）. On the event study analysis, we find that the Japanese capital market has shown a statistically significant negative reaction to the press reports. This result is due to a strong distrust of corporate activity regarding TP strategies. Moreover, in order to clarify the reason why the market responds to reports of TPT being applied, we compute the cumulative abnormal returns （CARs） around the date of the press report and conduct two-stage least-squares estimation to examine where this result regarding the market reaction comes from. Our results indicate that the variables for intangible assets and effective tax rate and the variables which represent the extent of corporate governance （CG） are statistically significant with respect to these reactions.
文摘A goal of transfer pricing may be to maximize after tax revenue by setting transfer prices that reduce the total tax paid. ＂Transfer pricing＂ is the pricing of products or services provided by one division to other division of the same corporate entity. Most of the corporate entities are using the method of ＂Window dressing＂, which is a technique used in preparation of financial statements of corporate entities. A transnational corporation is any enterprise that undertakes Foreign Direct Investment （FDI）, owns or controls income gathering assets in more than one country, produces goods or services outsides its country of origin, or engages in international production. Profitability of the transnational corporate entities is being manipulated by the technique of transfer pricing. Abuse of transfer prices is a key tool used by the corporate entities to think that they have virtually no profit; hence, they shouldn＇t pay any taxes. India needs to realize the fundamental need for co-operation among tax administrations in order to remove the obstacles that international double taxation presents to the free movement of goods, services and capital between various countries. In this context, one needs to consider that transactions among associated enterprises may take place under different conditions from those taking place among independent enterprises, while enforcing the act of transfer price mechanism. This paper focuses on transfer pricing and its implications in transnational transactions.
