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  • The first section of this chapter mainly discusses the concepts of related enterprises , transfer pricing and transfer pricing regime , etc . the second section is on the arm ' s length principle ( a . l p . )
  • Protecting the interests of the goodwill opposite party and third party is the reason to research the appearing legal behavior and the need to be protected the normal transaction order and promote the honesty and credit
  • In conclusion , without a rational as well as feasible alternative principle , tax authorities should stick to " arm ' s length principle " . finally , this thesis expounds chinese laws governing intra - group transaction taxation a
  • This chapter argues that the traditional transaction methods , which base on and apply specifically the a . l . p . , will not be replaced by other methods , but they shall be complemented by some other methods due to their defectiveness in meeting the needs of complicated realities
  • The alternative " formula apportionment method " relates to the taxation sovereignty and economic benefit of countries concerned , and the application of mis method is also difficult . as a result , " formula apportionment method " is not widely adopted
  • The advantages of " arm ' s length principle " are as follows : arm ' s length price is market price , thus protects the interests of both intra - group transaction parties , moreover , the principle ensures the same tax treatment between the multinational enterprise and independent enterprise and comparatively fair distribution of tax payment among related countries
  • Analise the motivation of this system , including tax motivation and non - tax one . this discussion of the legal theory of transfer pricing tax system is based on the principle of equal tax , it also discuss the criterias of many other country ' s related enterprises . examine , evaluate the principles of current transfer pricing law control , including total profit principle , arm ’ s length principle , comparable principle , , as well as the solution provided by foreign country ' s related enterprises , such as comparable uncontrollable pricing method ; resale pricing method ; cost - plus method , and analise their advantages and disadvatages . it compares the transfer pricing tax system amoung development countries , and therefore putforword the related problem of china and provide solutions
  • This thesis then expounds the concept and applying methods of generally adopted " . arm ' s length principle " , probes into several important problems of comparability analysis , adjustment and information exchange in the application of " arm " s length principle " , elaborates on the application of the prin ciple to four types of intra - group transactions , including tangible transaction , intangible transaction , loan and service , and then analyzes the advantages and disadvantages of " arm " s length principle "
    随后本文结合立法和理论对内部交易税收立法的基本原则? ?正常交易原则的概念、适用方法和正常交易原则适用中的可比性分析、附属调整和情报交换等若干重要问题加以阐述,对正常交易原则具体适用于有形资产交易、无形资产交易、贷款和劳务提供等各类型内部交易加以详述,并在此基础上对正常交易原则的利弊进行分析。
  • In order to assure the quality of power supply and pertinent service level , and then ensure the normal dealings between utility companies and customers in rated limits , it is indispensable to put a penalty or a premium due to the effect of a customer , which embodies the corporate responsibility for power quality
  • The disadvantages of " arm ' s length principle " are as follows : the theory is not sound and the application is rather difficult . from the angle of theoretical basis , multinational enterprises often employ centralized management , in other words , parent companies often have control over interdependent subsidiaries , thus produces scale economy , which differentiates from independent enterprises . in this sense , the infra - group transaction and the uncontrolled transaction are incomparable
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