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最近,笔者走访了大连市一家较有声誉的税务师事务所,了解到这样一件事情,该所服务十年的日资客户,解除了税务顾问服务合同,起因是客户对事务所提供的转让定价服务不满意。由于近年来大连市国税局加大了对关联公司转让定价业务的调查力度,该企业担心受到税务机关的调查和调整,但对相关税收政策以及应采取哪些措施应对风险却不清楚,因而向事务所提出顾问要求。事务所就转让定价定义、性质、目的、调整风险的判断、对企业的影响以及应采取的
Recently I visited a reputable tax office in Dalian and learned of the fact that the ten-year Japanese service customer lifted the tax consultancy service contract because of the transfer the client provided to the firm Pricing service is not satisfied. In recent years, Dalian Municipal State Administration of Taxation has intensified the investigation on the transfer pricing business of the affiliated companies. The enterprises are worried about being investigated and adjusted by the tax authorities. However, it is unclear the related tax policies and the measures to be taken to deal with the risks. Therefore, Adviser’s request. Firm’s definition of transfer pricing, nature, purpose, judgment of risk adjustment, impact on business and what should be taken