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近三年来,海关将进口货物审价的重点转向了特殊关系影响成交价格的审查,特别存在转让定价安排的龙头跨国企业是海关审查的重要对象。由于海关往往倾向于认定企业整体利润率过高是因为进口价格过低导致,需要调高进口价格补税;而税务机关恰恰相反,倾向于防止利润率过低侵蚀所得税税基。现有海关和税务机关各自的价格预裁定和预约价格安排机制虽可在一定程度上提高企业对执法的预见性,但是由于缺乏协调机制,在两部门相互冲突的税收目标下,跨国企业制定转让定价安排仍然面临不确定的税务负担和冲突的审查标准。而且,实践中海关很少对价格作出预裁定,预裁定更多被应用于归类领域。

2022年5月18日,深圳海关和国家税务总局、深圳市税务局联合发布了《关于实施关联进口货物转让定价协同管理有关事项的通告》(深关税〔2022〕62号)旨在解决这一问题。据悉,本次协同管理系在海关总署和国家税务总局共同指导下形成的全国首例海关、税务转让定价协同管理的方案(简称“本次方案”),很可能对其他地方的海关和税务机关形成示范、推广效应,非常值得存在转让定价安排的关联进口企业,特别跨国企业的关注。为此,欧盟商会南京分会特邀德勤海关、税务专家结合过往应对海关转让定价审查的经验对本次方案中的重点内容做出分析、解读,供相关企业参考。

In the past 3 years, due to the lack of coordination mechanism, transnational enterprises still face uncertain tax burden and conflicting examination standards when making transfer pricing arrangements under the conflicting tax objectives of the Customs and the Taxation Bureau. Moreover, in practice, the customs seldom makes a preliminary ruling on the price, and the preliminary ruling is more used in the field of classification.

On May 18, 2022, Shenzhen Customs, the State Administration of Taxation and Shenzhen Municipal Taxation Bureau jointly issued the Notice on Matters Related to the Implementation of the Coordinated Management of Transfer Pricing of Related Import Goods (Shenzhen Tariff [2022] 62) to address this problem. It is reported that this coordinated management is the first coordinated management scheme of Customs and tax transfer pricing in China under the guidance of the General Administration of Customs and the State Administration of Taxation (referred to as "this scheme"), which is likely to have a demonstration and promotion effect on customs and tax authorities in other places, and is very worthy of the attention of related import enterprises with transfer pricing arrangements, especially multinational enterprises. Therefore, the European Chamber Nanjing invited the experts from Deloitte to review the customs transfer pricing and interpret the key content of this program combining with the past experience.

  • 2023-06-20 | 15:00 - 16:30
  • Deloitte Nanjing Office

European Chamber Nanjing Chapter is delighted to extend an invitation to an exclusive talk with a distinguished guest, Mr. Pit Heltmann, the Consul General of the German Consulate in Shanghai.

  • 2023-06-16 | 15:00 - 16:30
  • 38F Lobby Lounge, Ritz-Carlton Hotel Nanjing 南京丽思卡尔顿酒店38层大堂吧
Members only

Compensation management is a very important part of human resource management, which plays an irreplaceable role in attracting and managing talents. This event will present you the compensation status in 4 key specific industries from various angles.
薪酬管理是人力资源管理中非常重要的一部分,在吸引人才、管理人才方面发挥着不可替代的作用。本次活动将通过多角度向您展示4个重点行业的薪酬状况。

  • 2023-05-30 | 08:30 - 10:30
  • 7F, VIP room, Sofitel Nanjing Galaxy Suning 索菲特苏宁银河大酒店7层自助餐厅VIP Room

The European Chamber Nanjing is pleased to invite you to join the factory tour to GAMI Suzhou and tesa China. During this event, the chamber's latest report China’s Innovation Ecosystem: The localisation dilemma will be launched.

  • 2023-05-17 | 14:15 - 16:35
  • GAMI Suzhou office

The European Chamber Nanjing Chapter will hold the Annual General Meeting on April 27. And at this meeting we will also hold 2023/24 Sourcing Nanjing Forum Chair and Vice Chair Elections

  • 2023-04-27 | 15:00 - 18:00
  • Jin'Ao Ballroom I, Fairmont Nanjing

The European Chamber Nanjing is pleased to invite you to join the factory tour to Leitz China plant in Jiangning and meet the local board candidates. You could also choose to meet the candidates online.

  • 2023-04-21 | 14:15 - 16:30
  • Leitz China

In recent years, the "clear" special action launched annually by the Cyberspace Administration has been deepened year by year to purify the network public opinion environment from all dimensions. The special action in 2023 even puts forward the slogan of "optimizing the business network environment to protect the legitimate rights and interests of enterprises", which is aimed at bad online behaviors that are harmful to the reputation of enterprises.
However, the enterprise really rest assured from now on, not afraid of public opinion? As can be seen from the latest case of corporate reputation rollover, the core of corporate reputation management lies in its own management ability, and the real driving force of corporate reputation rollover is not the media or we media, but the consumers of enterprises.
In order to truly prevent public opinion crisis, the enterprise can not blame the network environment, constantly improve the team's reputation management level, make the work routine, process, is the long-term work of the enterprise.
This seminar will provide you how to analysis about the latest PR crisis cases and media environment changing.

  • 2023-04-19 | 14:00 - 16:00
  • European Chamber Nanjing Office

The European Chamber Nanjing is pleased to invite you to join the factory tour to SUSPA new plant in Jiangning.

  • 2023-02-24 | 14:15 - 16:20
  • SUSPA Nanjing Plant

European Chamber is delighted to invite you to join the “Tour to Longtan Port and Roundtable Discussion with Jinling Customs”, which will be held on Feb 16, 2023 in Nanjing. This will be a wonder opportunity for you walk in person into Longtan Port container terminals, railway stations and other service facilities, as well as to have roundtable discussions with Jinling Customs, learning about the services of China-Europe Railway Express and the incentive policies, having your questions answered by the relevant authorities.

  • 2023-02-22 | 13:30 - 16:15
  • Longtan Port

In cooperation with the Changzhou International Managers Forum, European Chamber Nanjing Chapter attempts to bring useful information for members and friends in Changzhou again.

  • 2023-02-15 | 18:30 - 20:30
  • Sheraton Changzhou Xinbei Hotel