Divergence And Harmony Between The Special Tax Adjustment And Customs Valuation Of Imports Of Transfer Pricing

Due to the countries all over the world mainly adopt tax imposition object asstandard tariff, so it is important to determine the dutiable value of import and exportgoods, and also affect the calculation of import link value-added tax, consumption tax.To determine the import and export goods customs duty assignment process calledcustoms valuation. Tax authorities need to be based on arm’s length principle to adjusttransactions between related parties of revenues and expenses. Relationship does notinfluence the reasonable distribution of the profits between both parties, and suchprocedures constitute the transfer pricing adjustment system. This thesis mainlyfocuses on the connections between abovementioned two systems. The preamble aimsto clarify the focus of research and research ideas. The discussion in this thesis isdivided into six parts as the five chapters thereof, and then comes the conclusion.The first part is the theoretical basis and the main study of transfer pricing andcustoms valuation. Think of the relationship between the two are complementaryrelationship and contradiction.Comparative study is carried out in whole Chapter two to study the systems ofcustoms valuation and transfer pricing in an all-round way. Comparisons betweenthese two systems are carried out in the principle of association standards, applicableadjusting method, and other aspects of the comparison. It is concluded that betweentwo sets of laws in common, are the basis of coordination between two sets of rules.The third part analyzes the applicable method of the existing problems of "WTOcustoms valuation agreement "and "OECD transfer pricing guide".whether or noteach other can make concessions. Mainly from two perspectives, the first is themethod of Customs Valuation comparability studies; the second is whether thetransfer pricing adjustment method can obtain a fair price profit.The fourth part mainly introduces the international organization of customsvaluation system, and the production of transfer pricing adjustment has been madeand the concrete practice of abroad. From the United States, South Korea, Canada,introduces the concrete practice of the three countries, finally summarizes theexperience for reference.The fifth part introduces two cases about the customs to borrow transfer pricingmethods, summarize the current understanding of the experience.The sixth part through the research of this article, summarizes coordination disorder between customs valuation and transfer pricing in three areas of our country,and finally put forward feasible suggestions accordingly.