A Study On APA Based On Optimizing Transfer Pricing Management

The world today is an era of economic globalization.Multinational corporations are the main players and promoters of economic globalization.However,in order to maximize their own profits,some multinational corporations often abuse transfer pricing methods to avoid paying taxes.Follow-up adjustments and audits are severely countered.In order to mediate the contradiction between the tax authorities in charge and transnational taxpayers,establish a harmonious relationship between taxation and taxation companies,and coordinate the distribution of tax bases between countries and countries,appointing pricing came into being.APA changes the traditional mode of transfer pricing afterwards supervision to the prior consultation mode.This mode not only fully considers the taxpayer's legitimate interests,but also reduces the taxation and collection costs of the tax authorities,and helps to build a harmonious solicitation relationship.Achieve a win-win situation for tax companies.China's APA has been continuously developed since its implementation.However,the theory and practice of all aspects of APA in China are not yet mature.It should be said that there are still large gaps compared with developed countries,and it needs to be continuously improved.This paper takes the application of APA in our country as the core.Firstly,it describes the type,applicable subject and applicable principle of APA,analyzes the necessity of APA in China and its application in China.Then,the specific case of S Machinery Manufacturing Co.,Ltd.was introduced,and the basic situation of S company,the principle of transfer pricing adjustment,the calculation method,and the procedure of the APA were detailedly analyzed.This paper analyzes the problems in the application of A-subscription pricing in S company and analyzes the reason why this arrangement is difficult to implement nationwide.It mainly analyzes the problems existing in the practical application of China's APA in three aspects:law,practice and supporting soft environment.In response to these problems,this paper proposes to establish a stronger legal security system,clarify and improve the legal status and role of the subscription pricing,promote flexible and flexible application management model,and actively encourage transnational taxpayers to apply for double(multi)side booking pricing agreement.Comprehensively upgrade the supporting soft environment project,establish a unified database of reservation pricing,and give full play to the role of tax mediation and other measures to further optimize and improve China's APA.