第21章必講后備國際稅收環(huán)境與轉移定價(文件)
【正文】 stic firm. ? Consider the example of a firm that has one division that mills lumber（加工木材） and another that makes furniture. The transfer price of the lumber is a political as well as economic and accounting issue. 2131 Transfer Pricing Related Issues For MNC, there exists the added plications of: Differences in tax rates. Import duties and quotas. Exchange rate restrictions on the part of the host country. Most countries have regulations controlling transfer pricing. ? In the ., the tax code requires transfer prices to be arms length prices（公平價格，獨立企業(yè)間的交易價格） . 2132 Arms Length Price ? A price that a willing seller would charge a willing unrelated buyer. ? The IRS prescribes three methods for estimating an arms length price ? Comparable uncontrolled price. ? Resale price: the price at which the good is resold by the affiliate is reduced by overhead（經常性費用） and profit. ? Costplus approach: an appropriate profit is added to the cost of the manufacturing affiliate. 2133 轉移定價案例應用 Mintel制造公司生產的產品從母公司輸送到海外全資子公司進行銷售。 對控股國外公司的所得要立即征稅 。 2127 中國對外投資主要目的地 2128 Controlled Foreign Corporation 美國居民控股的國外公司是指美國股東擁有 50%以上表決股份的外國子公司 。 Allows taxpayers to recover somewhat from double taxation. Direct foreign tax credits are puted for direct taxes paid on active foreignsource ine of a foreign branch of a . MNC or on withholding taxes withheld from passive ine. Indirect foreign tax credits are for ine taxes paid by the subsidiary. 2122 Examples of Calculating . Foreign Tax Credits for Subsidiary Operations 2123 Organizational Structures for Reducing Tax Liabilities Branch Subsidiary Ine（分公司及子公司的收入） Payments to and from Foreign Affiliates Tax Havens Controlled Foreign Corporation Foreign Sales Corporation 2124 Branch Subsidiary Ine ? An overseas affiliate of a . MNC can be anized as a branch（分公司） or a subsidiary（子公司） . ? A foreign branch is not an independently incorporated（獨立成立的） firm separate from the parent. ? Branch ine passes directly to the parent’s ine statements. ? A foreign subsidiary is an affiliate anization of the MNC that is independently incorporated. ? Ine may not be taxed in the . until it is repatriated（被返回） , under certain circumstances. 2125 Payments to and from Foreign Affiliates ? Having foreign affiliates offers transfer price tax arbitrage strategies. ? The transfer price is the accounting value assigned to a good or service as it is transferred from one affiliate to another. ? If one country has high taxes, don’t recognize ine there— have those affiliates pay high transfer prices. If one country has low taxes, recognize ine there— have th
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