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d for identification and tracking of orders. Orders for meals and drinks are taken by waiting staff using a personal digital assistant (PDA) device that municates directly over the wireless network with the kitchen IT system. Chefs use the kitchen system to schedule food preparation for each table. The cashier refers to the kitchen system when billing customers. Approximately 75% of sales are paid for using credit cards。 the remaining 25% is paid for in cash. Accounting clerks take the records of sales from the kitchen system and enter the transactions in the separate accounting system. Cash is periodically banked.When planning the tax audit of a restaurant like Toscani, auditors focus on specific risks associated with audit objectives. For example, mon approaches to evade tax include understating restaurant sales by not recording all kitchen sales in the accounting system, and overstating purchases of meat, vegetables, etc. Sales paid for by credit card are easily traced by the tax auditor to bank records, but cash sales can be untraceable if they are not recorded in the accounting system. Purchases of ingredients for cooking meals can be overstated by entering overstated amounts, entering duplicate transactions or by purchasing excess meat and vegetables for the kitchen, but taking these for consumption at home.CAV software can be used to perform many different types of tests and other functions when the auditee’s data is in electronic form. These are described in Table 2, with examples relevant to the audit of Toscani. It is assumed that electronic records from the kitchen system, accounting system and bank statements are available.Table 2 – Tests in Toscani audit using CAV softwareFunctionDescriptionTest using CAV for ToscaniAudit ObjectiveVerifying extensions and totalsIndependent calculation of amounts and totalsIndependent calculation of sales for each customer using kitchen orders and pricing.Independent calculations of total sales for each day using kitchen data for parison with similar totals recorded in the accounting system.AccuracyCompletenessClassificationFiltering Displaying records that meet specified criteriaIdentifying payments to vendors within 4 days of the end of the fiscal year for examination for proper cutoff.CutoffJoiningCombining and/or paring files with mon fields.Comparing individual sales through the kitchen system to recorded sales in the accounting system.Comparing payments to vendors in the accounting system with payments reported in the bank statements.CompletenessOccurrenceSamplingApplying statistical sampling methods to select items for further examination, and to project sample results to the populationSelecting a statistical sample of purchase transactions for tests of proper authorisation, and occurrence, emphasising large amounts but with a random sample of smaller amounts.Projecting sample errors to the population for parison with tolerable errors.OccurrenceSummarisationSummarising records with subtotalsSummarising sales figures for each day of the week, for each week and over time.CompletenessClassificationCAV software is now widely used by the ATO. It has proved to be a useful plement to normal manual procedures. All tax audit staff will eventually be trained in CAV software. A specialist CAV support division is available to assist the auditee in data extraction and audit staff in application of the software.Some examples of the successful use of CAV software by the ATO include: Detection of sales wrongly classified as export sales. No Goods and Services Tax (GST) is to be remitted to the ATO on export sales. CAV software can be used to examine customer addresses to identify those with an Australian address, and sales that are not eligible for treatment as export sales. Detection of duplicate claims for expenses by related entities. These entities operating within a group often have very similar names. The vendor invoices payable by one such entity may claimed as an expense by more than one entity. CAV software can review the records of each entity and look for duplicates. Detection of incorrect recording of interpany transactions between related entities. CAV software can match purchase and sales transactions between related entities to ensure they are recorded correctly for each pany. Checking the calculation of GST. CAV software can independently check the calculation of GST Collected and GST Paid on all recorded sales and purchase transactions. 5.ConclusionThe tax auditor must decide whether or not to use CAV software and how to use it. The auditor must be familiar with the functions of this CAV software and be able to recognise opportunities to apply these functions to test audit objectives. This is a professional judgment. The auditor will consider whether the audit tests can be performed manually and also whether using CAV software will allow the auditor to perform these tests more efficiently.BibliographyA A Arens, P J Best, G E P Shailer, B Fiedler, R Elder amp。 M Beasley (2007) Auditing and Assurance Services in Australia: an Integrated Approach, Seventh Edition, Pearson Education.Australian Taxation Office (2007) Computer Assisted Verification, (Affiliation:University of Southern Queensland,Faculty of Business,Australia)臺灣股票上市公司產業(yè)移轉定價之研究謝耀智 黃定遠摘 要:臺灣企業(yè)為了獲取較低的原物料供應成本以降低生產成本、開拓市場、爭取市場佔有率以及獲得先進技術等理由,而紛紛前往大陸設廠投資,已是不爭的事實。而企業(yè)為了獲取更高的利潤,必定設法降低稅負或成本,又依所得稅法第四十三條之一之規(guī)定,臺灣企業(yè)赴大陸投資,大都為關係企業(yè),並且極可能以採移轉訂價來規(guī)避稅負。本研究以臺灣經濟新報文化事業(yè)股份有限公司(Taiwan Economic Journal Co., Ltd.)19972006年國內上市公司財務(季報)資料庫,蒐集其一般產業(yè)、上市基本資料,經過篩選後,共計取得樣本公司331家。以Probit 模型檢測影響企業(yè)採用移轉訂價的因素,並檢測各產業(yè)採用移轉訂價的因素是否有差異。關鍵字:移轉訂價;關係企業(yè);非常規(guī)交易;租稅規(guī)劃。一、緒論臺灣是海島型經濟體,仰賴出口為臺灣賺取外匯,而今「企業(yè)全球化」已是世界潮流,當企業(yè)為了獲取較低的原料物供應成本以降低生產成本、開拓市場並爭取市場佔有率以及獲得先進高技術等理由,不斷向外擴張,企業(yè)從單一企業(yè)擴張成為集團企業(yè)甚至跨國企業(yè)等較為複雜的組織型態(tài)。而隨著組織型態(tài)的轉變,關係企業(yè)或跨國企業(yè)對於公司間或國家間移轉其營業(yè)、投資與融資活動更能彈性的應用。企業(yè)對外投資之動機雖未必與租稅目的有關,但因