國際稅法中預約定價問題研究
發(fā)布時間：2019-04-02 18:45
【摘要】：在經(jīng)濟全球化的背景下,跨國公司的經(jīng)濟活動對全球經(jīng)濟的影響日益深遠。跨國公司在世界各地設(shè)立眾多的分公司、子公司等與之相關(guān)聯(lián)的經(jīng)濟實體,不僅僅能夠從世界范圍內(nèi)對其資源進行優(yōu)化、整合,創(chuàng)造更多的利潤,同時,還利用各國的稅收優(yōu)惠等社會政策資源,達到國際避稅的目的,其中,轉(zhuǎn)移定價是跨國公司避稅的重要手段。在國際稅法領(lǐng)域,如何合理有效地規(guī)制跨國公司轉(zhuǎn)移定價的問題,保護稅基不被侵蝕,對世界各國來說都是一個重要的問題。預約定價是應對跨國公司轉(zhuǎn)移定價從而進行調(diào)整的一種方法,由于其相比其他調(diào)整方法具有的方便公司交易、有利于稅務機關(guān)管理等優(yōu)勢,使得其被越來越多的國家的稅務機關(guān)所采用。對于我國的預約定價安排立法上, 2007年出臺的《中華人民共和國企業(yè)所得稅法》、2009年頒布的《特別納稅調(diào)整實施辦法(試行)》等一系列法律法規(guī)都對預約定價進行了明確的規(guī)定;實踐中,已經(jīng)逐漸引入了雙邊、多邊預約定價安排,然而其中也不乏缺憾。本文通過對預約定價的研究,對完善我國稅制、保證我國稅收提出建議。
[Abstract]:Under the background of economic globalization, the economic activities of transnational corporations have an increasingly far-reaching impact on the global economy. Multinational corporations set up numerous branches, subsidiaries and other related economic entities around the world, not only to optimize and integrate their resources from around the world, to create more profits, but at the same time, The purpose of international tax avoidance is achieved by utilizing the social policy resources, such as tax preference and so on, in which transfer pricing is an important means for multinational corporations to avoid tax. In the field of international tax law, how to regulate the transfer pricing of transnational corporations reasonably and effectively and protect the tax base from being eroded is an important problem for all countries in the world. Reservation pricing is a method to adjust the transfer pricing of multinational corporations. Due to its advantages over other adjustment methods, it is convenient for company transactions and conducive to the administration of tax authorities, and so on. It has been adopted by tax authorities in more and more countries. In terms of the legislation of reservation pricing arrangements in China, the Enterprise income tax Law of the people's Republic of China was introduced in 2007. A series of laws and regulations, such as the measures for the implementation of Special tax Adjustment (trial) promulgated in 2009, have clearly stipulated the reservation pricing; In practice, bilateral and multilateral reservation pricing arrangements have been gradually introduced, but there are many shortcomings. Through the study of reservation pricing, this paper puts forward some suggestions to perfect our tax system and guarantee our country's tax revenue.
【學位授予單位】：中國政法大學
【學位級別】：碩士
【學位授予年份】：2011
【分類號】：D996.3;D922.22;F812.42
本文編號：2452817
[Abstract]:Under the background of economic globalization, the economic activities of transnational corporations have an increasingly far-reaching impact on the global economy. Multinational corporations set up numerous branches, subsidiaries and other related economic entities around the world, not only to optimize and integrate their resources from around the world, to create more profits, but at the same time, The purpose of international tax avoidance is achieved by utilizing the social policy resources, such as tax preference and so on, in which transfer pricing is an important means for multinational corporations to avoid tax. In the field of international tax law, how to regulate the transfer pricing of transnational corporations reasonably and effectively and protect the tax base from being eroded is an important problem for all countries in the world. Reservation pricing is a method to adjust the transfer pricing of multinational corporations. Due to its advantages over other adjustment methods, it is convenient for company transactions and conducive to the administration of tax authorities, and so on. It has been adopted by tax authorities in more and more countries. In terms of the legislation of reservation pricing arrangements in China, the Enterprise income tax Law of the people's Republic of China was introduced in 2007. A series of laws and regulations, such as the measures for the implementation of Special tax Adjustment (trial) promulgated in 2009, have clearly stipulated the reservation pricing; In practice, bilateral and multilateral reservation pricing arrangements have been gradually introduced, but there are many shortcomings. Through the study of reservation pricing, this paper puts forward some suggestions to perfect our tax system and guarantee our country's tax revenue.
【學位授予單位】：中國政法大學
【學位級別】：碩士
【學位授予年份】：2011
【分類號】：D996.3;D922.22;F812.42
【引證文獻】
相關(guān)碩士學位論文 前1條
1 于夢晨;關(guān)聯(lián)企業(yè)國際避稅若干法律問題研究[D];中央民族大學;2012年
，本文編號：2452817
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