特别纳税调整

第六章特别纳税调整

Chapter VI Special Adjustments to Tax Payments

我国转让定价制度的新突破&基于新《企业所得税法》特别纳税调整的分析

New Breakthrough of China 's Transfer Pricing System Based on Analysis of " Special Tax Adjustment " in New Enterprise Income Tax

这部分主要是对涉外特别纳税调整规则进行补充说明，力图让整篇文章保持叙述完整丰满。

This section is mainly to the foreign special tax adjustment rules , and tries to make , adding that the whole article keep narrated complete plump .

第五部分其他特别纳税调整措施，简要介绍了转让定价规则、成本分摊协议管理规则以及一般反避税条款。

The fifth part of the " other special tax adjustment measures " were introduced briefly , transfer pricing rules , cost allocation and management rules commonly agreement tax provision .

随着新《企业所得税法》以及《特别纳税调整实施办法（试行）》的颁布，我国对反避税操作管理，特别是对转让定价的纳税调整作了全面的规范。

With the new " Enterprise Income Tax Law " and " Implementation Measures for Special Tax Adjustments ( Trial )" was promulgated , China made a comprehensive specification on counter-tax-avoidance operations , especially on tax adjustments for transfer pricing .

在企业所得税法及特别纳税调整办法不完备，不可能堵塞所有避税漏洞的条件下，国家制定特别纳税调整办法这种授权性规范，授予税务机关为反避税而进行纳税调整的执法权。

Under the condition that the " enterprise income tax law " and the special tax adjustment approaches could not possibly plug all the avoidance loopholes , the special tax adjustment rules serve as an authorized norm , granting the tax authorities with the executive power of anti-avoidance tax adjustment .