可比非受控价格法的案例分析(国外英语资料).doc

可比非受控价格法的案例分析(国外英语资料) Special tax of comparable uncontrolled price adjustment in the case (2009-04-09 09:34:02) reprint print Tags:. Shaw, Forshaw, longevity (editors note: the author Xiao Taifu, doctor of law, Beijing Taifu law office, engaged in practicing law for fourteen years, is a senior lawyer, the higher the theory level and rich experience specializing in enterprise mergers and acquisitions services and tax law. Dr. Xiao Taishou, taxation, Beijing Futai tax office executive director, has rich experience in tax planning. If the tax payment or tax avoidance of doubt, you can contact with or or 01063332899and Dr. Xiao Taishou) The non controlled price approach is a method of comparing the price of an asset or service transferred in a controlled transaction under comparable conditions to the price of an asset or service that is transferred in an uncontrolled transaction. If the two prices are found to differ, indicating that the underlying transaction price of the underlying firm is problematic, the price in the uncontrolled transaction can be used instead of the price in the controlled transaction. That is to say, the so-called non controlled price law refers to the method of calculating and adjusting prices according to the same or similar business activities between independent enterprises. Or the method of adjusting the price charged by the non associated parties with the price charged by the same or similar business activities as the fair transaction price. It can be applied more widely than the non controlled price method. It can be applied to tangible property transactions and intangible assets such as intangible assets and intra group labor services, but it is the most widely used in the field of tangible property. However, the method is generally difficult to operate, and as long as there are factors in the two transactions are not comparable, the method is not easy to adopt, in practice, we should pay attention to the following situati