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Currently the penalties for default with respect to transfer pricing are very high. Penalties to the tune of 100 to 300% of the additional tax and 2% penalty of international transactions for documentation are very commonly levied on defaulting parties. It is observed that these penalties are significantly high [46] . Even though high penalty rates prove to be exemplary punishments, they tend to have adverse effects in the field of taxation. The authors recommend that the stringent penalties be lowered and rationalized to ensure a more effective implementation of the taxation laws.

4.4转让定价在西部和经合组织的角色——4.4 Transfer Pricing in the West And OECD'S Role

Transfer pricing being a concept of international character, has to be read with practices across different countries for thorough understanding. The Organization for Economic Cooperation and Development (OECD) first took note of the practice of transfer pricing in the year 1979 by publishing its report on the subject. On July 27, 1995, the OECD released the first draft of its transfer pricing guidelines. These have been updated in July, 2010 [47] .? The OECD has adopted the principle in Art 9 of the OECD Model Tax Convention, to ensure that transfer prices between companies of multinational enterprises are established on a market value basis. It provides the legal framework for governments to have their fair share of taxes and for enterprises to avoid double taxation on their profits.? The guidelines are voluntary in nature and serve as an international model code for countries to use as a base for their own customized domestic tax laws for regulating transfer pricing. Nonetheless, most member countries do not have their own detailed transfer pricing regulations and rely on OECD Guidelines. Over 60 governments have adopted the transfer pricing rules [48] .

英国——UNITED KINGDOM

The English domestic law contains general and special provisions on transfer pricing issues within Schedule 28AA of the Income and Corporation Taxes Act, 1988 [49] and Part 4 of the Taxation Act, 2010 [50] . They deal with transactions between any two persons under 'common control'. The provisions effectively incorporate OECD Model Tax Convention's Article 9 and the OECD Guidelines into domestic law and extend the arm's length standard to all transactions between related parties. The transactions are defined to include 'arrangements, understandings and mutual practices (whether or not they are intended to be legally enforceable).' In comparison to Indian transfer pricing regulations, it can be said that the scope of the U.K. Act is wider when it comes to the coverage of the 'related party transactions.' Where the Indian regulations have clearly laid down specific instances and transactions which would amount to a related party transaction, the U.K. regulations have used broader terms while describing a transaction that would be considered a related party transaction; or in other words, transactions between parties under common control. They also include a series of transactions, including third party transactions, in pursuance of or in relation to the arrangements. There are no specific statutory rules on how the arm's length prices are to be determined, or on the documentation or penalties relating to transfer pricing本论文由英语论文网提供整理，提供论文代写，英语论文代写，代写论文，代写英语论文，代写留学生论文，代写英文论文，留学生论文代写相关核心关键词搜索。