Apas International Comparison

With the world economy uniting swift, the business among the multinational corporations is more and more frequently. Transfer pricing is a common way of tax avoidance. In allusion to this status, most of countries make the transfer pricing tax regime to solve it. But the transfer pricing is a kind of post-modification mode, it has many flaws. Under the background, advance pricing agreement or advance pricing arrangement came into being. At present, many countries have established and executed the advance pricing agreement. The APA of the USA,Japan and Australia is representative among them. Our country has a short history of APA, and we still need to quest for it frequently. We should refer to plenty of experience of foreign countries and consummate the APA system, which is a certain program in the development of our APA system.Under this background, this paper introduces the APA system of the USA,Japan and Australia and makes a comparison among them. The writer hopes some viewpoints in this paper can promote the development of our APA system. This paper mainly includes four chapters:Firstly,the conception and the rise of the APA. Introduce three different theories about the APA, and make a comparison among them. Then, introduce the background of the rise of the APA. The advance pricing agreement system is the inevitable offspring with the development of the transfer pricing tax regime.Secondly,the international practice of the APA. Most of countries accepted and executed the APA after it generated. This part introduces the present situation of the APA and the APA system of the USA,Japan and Australia separately, including the framework of organization and the procedure of APA.Thirdly,the commonness and the difference of the APA. This part summarizes five commonness and three differences on the basis of the description about the three countries in the second part.Fourthly,the revelation to our country by the international comparison of the APA. Introduce the development status of the APA in our country firstly and the question now. In the end, put forward several suggestions about the APA by learning the mature experience of the USA,Japan and Australia. Including pushing the APA system steadily,changing the management mode,consummating the APA system,establishing the perfect information system and strengthening the international cooperation.