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双边预先定价须遵循国际法原则,同时满足国内法要求;双边预先定价体现经济发展优于税收利益的理念,贯彻法治和诚信原则,需要灵活务实的合作态度,重视公开透明和合理的程序。目前我国对双边预先定价尚缺乏足够的法律支持,税务管理模式面临挑战,现有人才储备严重不足,因此应确立双边APA原则体系和操作体系,完善法律支持框架,并且重构转让定价税务管理模式,加大人才培养力度。
Bilateral pre-pricing should follow the principles of international law and meet the requirements of domestic law. Bilateral pre-pricing reflects the idea that economic development is superior to tax revenues. Implementing the principle of rule of law and good faith requires a flexible and pragmatic cooperative attitude and attaches importance to open and transparent procedures. At present, China still lacks adequate legal support for bilateral pre-pricing. As the tax management model is facing challenges and the existing personnel reserve is seriously inadequate, a bilateral APA principle system and operating system should be established to improve the legal support framework and to re-construct the tax management model for transfer pricing , Increase personnel training efforts.