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An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time [1] (called "Covered Transactions").
Chinese transfer pricing rules apply to transactions between a Chinese business and domestic and foreign related parties. A related party includes enterprises meeting one of eight different tests, including 25% equity ownership in common, overlapping boards or management, significant debt holdings, and other tests.
Exit taxation is also referred to as compensation for the "transfer of the place of business", remuneration for taking over functions, assets, risks and contracts with customers, payment for the take-over of part of the business, remuneration for the transfer of production and sales capabilities or transfer of profit potential. [2] [3]
The setting of the amount of related party charges is commonly referred to as transfer pricing. Many jurisdictions have become sensitive to the potential for shifting profits with transfer pricing, and have adopted rules regulating setting or testing of prices or allowance of deductions or inclusion of income for related party transactions.
International Commercial Law is a body of legal rules, conventions, treaties, domestic legislation and commercial customs or usages, that governs international commercial or business transactions. [1] A transaction will qualify to be international if elements of more than one country are involved. [2]
However, there is a waiver where the foreign corporation conducts a substantial business. New Zealand and Sweden [24] each have CFC rules, following a "grey list" and a "white list" approach, respectively. Australia has CFC rules similar to UK rules, but relies more on a "white list" of safe countries. [citation needed]
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Whereas appropriate transfer pricing of tangible goods can be established by comparison with prices charged for similar goods to unrelated parties, transfer pricing of intangible goods, products of intellectual efforts, rarely has comparable equivalents. Transfer prices then have to be established based on expectations of future income. [16]