The world economy border concept crumbles little by little, in the present time when the unification of the world-wide economic bloc is accelerated It is a tendency where also the transactions of import and export of the multinational corporation is increasing little by little.
Multinational enterprises is having the capital power which is enormous, The technical power which is excellent and The management ability which excels generally. For the maximization of profit it mobilizes all means and a method.
The international transfer price policy which is one of financial policies of Multinational enterprises is becoming the means which is important multinational enterprises fabricates a profit.
The international transfer price is intercompany transactions price of the multinational enterprises which the border is different
Like this, The custom authority have customs valuation system of this international transfer price.
Customs valuation is the process which decides the taxation price of tariff. Our country is the nation which joins to WTO customs valuation agreements which are an international norm of customs valuation. Customs valuation is provided in custom law 30th trillion ~ 35th trillion.
The transaction value (The first method) is the primary method of valuation which is based on the price actually paid or payable for imported goods, followed in sequential order by the alternate methods The second method which decides a taxation price at the transaction value of identical goods,
The 3rd method which decides a taxation price at the transaction value of similar goods,
The fourth method which decides a taxation price at the deductive value method.
The fifth method which decides a taxation price at the computed value method,
The 6rd method which decides a taxation price at the fallback method of valuation
Export or income between multinational enterprises is the transaction between special relationship enterprise
In about tariff evaluation of international transfer price of multinational enterprises with problem point and improvement program
First, Notice of Income commodity taxation price determination must be provided in Enforcement Ordinance or enforcement regulation.
Second, there is a possibility which there will be worry of taxation circle misappropriation of the custom authority. In order for the income voluntary right not to be infringed consequently unjustly, must strengthen a burden of proof.
Three, uncertainty and reasoning of taxation the transparency of the taxation which is caused by is low is fact in evaluation discord of Office of Customs Administration and National Tax Service transfer price. About hereupon trade name complement it regulates an evaluation discord in about transfer price of the multinational enterprises of the custom authority and the tax authorities and it makes the artificial flower, Long-term WTO customs valuation agreements and OECD it is tired and between it prepares WTO customs valuation agreements and OECD it is tired and an artificial flower plan and between the fact that it unifies the provision which conflicts is directly under most, it sees.
Four, must strengthen a first method application exclusion. Business data exchange activation it comes it means customs valuation must be professional with the mind specialty manpower cultivation for a new mind territory extension.
The research which it sees analyzes an customs valuation technique in about transfer price of the multinational enterprises and desirable hereafter operation direction under presenting boil, hereafter the low of escape stopped only the subject must solve. Consequently with the fact that the limit of the research which with propriety verification of the directions which have become escape from the research which tries to lead together the establishment of the detailed plan which is concrete becoming accomplished, sees a hereafter succeeding research will be overcome.