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目前各国都宣称对转让定价政策奉行公平独立原则(ALP)。发达国家更是制订了许多转让定价调整办法,并以贯彻ALP为由大力向全世界推行。但这些办法在实践中无法贯彻,根本原因是非营业竞争的关联交易定价不适用ALP,所谓的ALP是由各国各行其是地解释的。这使得ALP处于明知无用但又不能抛弃的尴尬境地。预约定价制不是医治转让定弊病的灵丹妙药。我国要注重八个方面以应对跨国转让定价中的ALP难题。
At present, all countries claim that the transfer pricing policy pursues the principle of fairness and independence (ALP). Developed countries have formulated a number of transfer pricing adjustment measures and implemented the ALP on the grounds that vigorously promote the world. However, these measures can not be implemented in practice. The fundamental reason is that the pricing of related-party transactions that are not business-related does not apply to ALP. The so-called ALP is interpreted by all countries on their own. This makes the ALP in the awkward position of knowing it is useless but can not be abandoned. Appointment pricing is not a panacea for the treatment of assaults. China should pay attention to eight aspects to deal with the ALP problem in transnational transfer pricing.