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自1996年我国实现人民币经常账户可兑换后,转让定价越来越成为跨国公司进行资本跨境流动的重要手段。由于其资金流动的隐蔽性,加大了外管当局对其监管的难度。预约定价作为一种转让定价税务管理的新方法,不仅可以用来防范跨国公司逃避税,还兼具防止跨国企业通过转让定价进行资本跨境转移的功能,因此可以考虑将其引入资本账户的监管。
Since China realized the convertibility of RMB current account in 1996, transfer pricing has become an increasingly important means for transnational corporations to carry out cross-border capital flows. Due to the hidden nature of its capital flows, it has made it more difficult for the foreign-control authorities to supervise them. As a new method of transfer pricing tax management, APA can not only be used to prevent transnational corporations from evade tax, but also have the function of preventing transnational corporations from transferring capital across borders through transfer pricing. Therefore, it may be considered to introduce them into the regulation of capital account .