Australia multinational transfer pricing tax admin

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Australia multinational transfer pricing tax administration Enlightenment

Companies are so difficult and complex addition, the original non-tax deductible interest calculation is based on reported annual 2oo'm7 · image bleed at the nose and steadily implement the integrated tax system base rock city, county agencies cause leather work, the decision mahjong Chen from the party point, discipline inspection team leader Feng hosted glass collected in advance of people of different dates plus the discussion repeatedly when the institutional reform program of care for 7 to discuss anti-summer, repair cause, and strive to make the program fit my bird city, county boast, to implement the IRS actual work. Text / Personnel Office Space / Xu Huizhong capital to calculate the degree of the last day, the taxpayers of this provision in the annual induction of two days before the end of large capital injection. A few days and then take away. Cause damage to the Australian Taxation Therefore, at present Australia is to be played from July boast change this in a controlled and calculated way than the guillotine, according to the method for calculating the two,[link widoczny dla zalogowanych], the Australian practice of transfer pricing inspiration to us have been in our anti-avoidance l0 years, anti-avoidance is gradually on track. Especially in recent years to increase the intensity of anti-avoidance work to continuously improve the law anti-avoidance provisions introduced transfer pricing management procedures associated enterprises, the development of anti-avoidance software, to strengthen anti-avoidance assessment, these measures are effective in promoting the work of anti-avoidance carried out. However,[link widoczny dla zalogowanych], compared with Australia, there are still shortcomings. Should further improve the management of transfer pricing (a) must as soon as possible to establish a highly centralized information system, which is working to promote the basic premise of anti-avoidance. Australia establish a national system of collection of tax information of large-scale information for all taxpayers. And the sub-sector management. At the same time the tax department and customs, industry will be thrown, securities and other departments networking, easy access to price and financial indicators related to information and focus on collecting relevant information through the Internet. This is their work for effective anti-avoidance basic guarantee. The constraints of the current anti-avoidance information on the bottleneck 2ooIm7 is not smooth, the main problem is the lack of a centralized to facilitate sharing of information throughout the system. Therefore, tax departments should also establish contact with the relevant departments together a wide range of information networks. (B) focus. Thorough and rigorous investigation of the enterprises transfer pricing audit. Sub-species of Australian Inland Revenue survey of transfer pricing audit focused on sales of objects arranged in the first one (within the top 30 multinational companies. At the same time. Australia has also implemented a fairly complete set of strict management method, Each company transfer pricing audit. are done strictly according to prescribed procedures, focusing on selected case analysis, risk assessment, industry benchmarking, functional analysis, examination and approval procedures. This \transfer pricing work, too much emphasis on the audit each year the number of households the number of enterprises, so some local households in order to complete the audit tasks, evasive, select small or easy to operate, easy to effective audit of the enterprise as the survey objects, arbitrary choice, using adjustment method is also too simple, the result is not the work of transfer pricing norms, but also voted against unscrupulous companies have a real deterrent, we work in the anti-avoidance in the future, should focus on the risk audit large multinationals as survey objects regulate the operation of the enterprise transfer pricing methods. In addition, the Inland Revenue Department ruled that transfer pricing should be set within the Commission. and to engage relevant experts to join the committee. (c) should improve the weakening of the relevant provisions of the present capital of Enterprise Income Tax Law , but production and operation requirements and the reasonable interest on the forefront of support in the income tax does not require the ratio of borrowed funds and capital as easily lead to weakening of foreign tax avoidance using capital. Therefore, revised tax laws in the future, it should be clear to prevent the weakening of capital the terms, only the business proportion of the borrowing and capital interest within certain limits, side allows tax deduction of interest payments in excess of this limit is not allowed in pre-tax deductions; and should be clear that controlled affiliates of shares. 50% of the total capital invested by calculation, calculated using the average loan balance calculation. (d) transfer pricing must be performed by the specialized agencies and specialized personnel to carry out the reform and opening has been 2O years, an increasing number of foreign-funded enterprises, the scale expanding only the implementation of professional management to ensure staff stability and continuity of work in order to help train highly qualified management personnel, and improve audit efficiency and quality. At present,[link widoczny dla zalogowanych], where a number of foreign-funded enterprises are concentrated,[link widoczny dla zalogowanych], with virtually no specialized agencies, personnel deployment confusion and uneven quality of personnel, greatly affected the conduct of the current anti-avoidance tax evasion in China's enterprises have been very serious,[link widoczny dla zalogowanych], an annual loss of about 70%. This bow I should be starting our attention, and take effective measures to prevent and combat.