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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.
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.
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]
ITR, previously known as International Tax Review, is a business-to-business publication focused on news analysis of tax policy and tax advice from around the world. This remit includes transfer pricing, corporate tax and indirect tax, particularly VAT and sales tax. [1]
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]
Direct tax in the form of an income tax was introduced by Sir James Wilson in India in 1860 to overcome the difficulties created by the Indian Rebellion of 1857. [12] The organisational history of the Income-tax Department, however, starts in the year 1922, when the Income-tax Act [4], 1922 gave, for the first time, a specific nomenclature to various Income-tax authorities.
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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").