| In international transactions, multinational companies make use of the different transfer pricing system to obtain tax benefits. It will inevitably lead to related countries actualize tax monitoring on the transfer pricing practices, resulting in the redistribution of tax benefits and benefit gambling launched for it. However, due to the complex nature of transnational corporations transfer pricing and the resulting information problem, the implementation of transfer pricing taxation is facing difficulties. Proceeds from this, basing on the perspective of balanced interests of relevant parties, this article researches for the effectiveness of the tax monitoring on transfer pricing, seeking the consistency between the taxation arrangements of international transfer pricing and the mechanism of tax collection. The text is divided into five chapters, with the exception of introduction, including the theoretical research and practice analysis. And, the second and third chapter study theoretically the system incentives of the international transfer pricing taxation and enforcement mechanisms; the forth and fifth chapter analyzes the foreign and domestic practice of transfer pricing taxation comparatively, and then the author brings forward the system of transfer pricing arrangements in our country.Chapter I is the introduction. This paper elucidates the significance of the main topics, the related areas definition, the literature summarize, the theory tools, research method, the basic ideas and logical structures, the innovation and lack of the article and so on.Chapter II is the system incentives of international transfer pricing taxation. This part analyzes mainly the international transfer pricing mechanism from the non- monitoring condition, and reveals the inner mechanism and external effects of arbitrage in the transfer pricing which multinational companies seek, and explores the system incentives of international transfer pricing tax. In the section I, the author discusses the scope of an international transfer pricing and further analyzes the theoretical basis of the international transfer pricing and the economic basis of transfer pricing options, which makes preparations for the follow-up analysis of international transfer pricing mechanism. The section II analyzes the mechanism of effect on the transfer pricing selection that the characteristics of the transnational corporation organization and difference of the external environment act on it, from the two-dimensional models including centralization and decentralization models. And the author shows the internal driving force that transnational corporations use the difference in external environments earning the profit. Section III gives the specific analysis of the external effects of the international transfer pricing and points out that the transfer pricing arbitrage interest action affects the revenue rights, market environment, foreign exchange balance and the interests of investors in the host country, and reveals the system cause of international transfer pricing taxation.Chapter III is the mechanism analysis of international transfer pricing taxation. This chapter analyzes the gambling balance of each related interest parties under the supervision of the transfer pricing tax, from two dimensions of the control afterwards and booking pricing, and reveals the mechanisms of institutional arrangements that achieve consistency in the transfer pricing taxation and collection mechanisms in the plight of the information. Section I briefly describes the scope of the international transfer pricing taxation, system and supervision effect, which prepares for the analysis of transfer pricing tax below the regulatory system plight. Section II analyzes the mechanism to balance the interests of relevant parties under the mode of transfer pricing adjustment afterwards. Firstly, establishes a supervision gambling model in which the state tax authorities and taxpayers are on the control of transfer pricing afterwards. Secondly, binding obligation enshrined in the cost-effective mechanism to balance; Secondly, introducing the types information types of monitoring intensity by tax authorities,the author analyzes the dynamic effect on the gambling balance by the tax authorities monitoring strength under the mode of transfer pricing adjustments afterwards. Finally, the section analyzes the impact on monitoring gambling balance by the behavior options in the related adjustment of the country's tax authorities. Section III analyzes the system plight in the control afterwards on transfer pricing. Firstly, this section analyzes the information plight faced by the gamble participants with limited sense and the adjustment disputes arising from the transfer pricing afterwards; Secondly, using a dynamic gamble model, the author analyzes the in -efficiency in the dispute settlement mechanism of transfer pricing adjustment afterwards under the restriction of the litigation costs. After a detailed analysis of the negative effects caused by the uncertainty of the transfer pricing control, the author advances the necessity of introducing the new tax collection mechanism. Section IV analyzes the actualizing mechanism of the booking pricing. Firstly, using the dynamic gambling model, the section analyzes the bargaining balance mechanism for the booking pricing; Secondly, from the perspective of non- synchronous contract, the author discusses the importance to creation of a mechanism to comply with self by the key assumptions, monitoring mechanism exit and re-formed consultative mechanism enactment; finally, the author make analysis on the limitations exist in such six aspects as the applying scope of booking pricing ,the cooperation with the monitoring level, the risk of government intervention, information problems, international cooperation and the choices of adjustment method.Chapter IV is the empirical study in abroad transfer pricing system. Basing on the review of the evolution of the inspection history of foreign transfer pricing tax, the author gives a comparative analysis on he present taxation system of the domestic and foreign transfer pricing taxation, and explores general law of the evolution in the international transfer pricing taxation, and focuses on optimizing the rational path of transfer pricing arrangements. Section I inspects the historical evolution of the foreign transfer pricing taxation, and reveals a country in the face of the dilemma choices whether protect the related tax benefits or protect the normal benefits of investors, through continuous innovation and improvement, there should gradually form two organizations in the United States and international economic cooperation in the complex process of transfer pricing taxation. In section II, choosing some major Western capitalist countries which are more representative in transfer pricing taxation as the object of study, the author makes a comparative analysis on foreign transfer pricing taxation, and reveals the commonness and differences in transfer pricing taxation of each country, and then the author gives a comprehensive review of the general trend of development in international transfer pricing taxation. Chapter V is an empirical study of transfer pricing taxation. In this chapter, on the basis of empirical analysis on historical evolution of transfer pricing taxation and the differences between foreign and domestic countries, the author brings forward the route arrangements of optimizing the transfer pricing taxation, combining with the actual situation of China's transfer pricing tax avoidance. Section I inspects the local historical process of evolution of the transfer pricing taxation from pilot to legislation, from the partial practice to the full implementation of practice. Through the horizontal compare in the legislative level, the specific content of foreign and domestic transfer pricing taxation, the section II reveals the diversity in transfer pricing system of china with the advanced international level, and establishes the reference by which China's reform of the transfer pricing system refers. Through the in-depth analysis of transfer pricing avoiding tax status in China, section III reveals the grim reality that the multinational companies make the transfer pricing avoiding tax in China, and reflects the necessity and urgency of the anti-avoidance. Section IV makes a series of arrangements on optimizing our system of transfer pricing, in order to achieve the consistency in collection mechanism with the transfer pricing system, efforts to build prior matter, after benign interaction between the taxation of transfer pricing mechanism.Through an in-depth study in the balance of interests on the international transfer pricing and taxation arrangement, this paper conduct a number of innovative explorations in the following areas:1. Innovation in perspective. Through screening literature, the author finds that "the study in revenue-driven transfer pricing" mainly from two perspectives:First, multinational corporations from the perspective of external factors on the impact of transfer pricing policy. Second, from the view of the tax authorities, the author discusses the economic impact of the transfer pricing system. From the perspective of research related to the interests balance, this paper analyzes the effectiveness of transfer pricing tax regulation, expands the horizons of international transfer pricing study.2, Establish a balance mechanism that supervision gambling model analyzes the control afterwards. In the supervision gambling model of the tax obligation, there have been many studies abroad and in our country, which are mainly centered on taxable enterprises, as well as how to monitor whether there is tax evasion and tax control design model. Based on the uniqueness of the international transfer pricing model, this paper has the following improvements: (1) supervision gambling model for the analysis of international transfer pricing tax avoidance, and on the assumption that there is no evasion of transnational corporations; (2) In addition to the adoption of tax evaded taxes, the obligation cost, fine used by the general tax evading model as measures of the cost involved, the income variable, but also introduces the revenue receipts, reputation loss and investigations success rate parameters; (3) introducing the types of information of the intensity of tax authorities monitoring, the author analyzes dynamic effect on the gambling balance by the strength of tax authorities monitoring under the model of transfer pricing adjustments afterwards; (4) introducing third-party involvement, this part analyzes the impact on the gambling balance by the options for action related to state tax authorities.3. From the view of information, this section analyzes the system plight in transfer pricing control afterwards. Aimed at the system plight in transfer pricing control afterwards, this paper gives some analysis as following from the view of information: (1) Since it is difficult to find comparable prices, and that the implementation of the normal trading exists principles information plight, although the system arrangements in the burden of proof and exchange of information have broaden the channels for obtaining information, the effect is not significant. (2) Facing information plight, although the innovation in the principle applied in transfer pricing adjustments, specific methods, comparable analysis will help make a judgment on the normal price of the deal according limited information, it has become a "double-edged sword", and the possibility of related party differences has increased, due to limited rationality; (3) Applying the dynamic gambling model, this paper analyzes the dispute settlement mechanism of transfer pricing adjustment afterwards, and points out that it is incredible of choosing the threat of litigation in the constraints of the high cost of litigation, and reveals that taxpayers will become disadvantaged in adopting judicial relief measures when face the transfer pricing disputes.4. With the gambling theory and contract theory, the paper analyzes the implement mechanism of booking pricing. (1) establishes a three-stage dynamic gambling model, analyzes bargaining gambling balance of booking pricing, and reveals the participants rational price formation mechanism under the double constraints of negotiations costs and the strict supervision by the tax authorities; (2) as a special tax lease, booking pricing agreement has a total of the characteristics of the time. Besides, it sets clear boundaries in the booking pricing agreements, and establishes a monitoring system to prevent the opportunistic behavior of escape in the implementation of obligations, so forms the formation of the mechanism of compliance with self. Specifically, it contains the key assumptions in booking pricing, the control mechanism, and the set of withdrawal and re-consultation mechanism.5, Basing on the analysis of transfer pricing taxation mechanism, the author puts forward his views in the optimization of taxation arrangement. (1) transfer pricing arrangements should combine organically the model of strict supervision afterwards with the booking pricing, and we should guarantee the consistency in transfer pricing taxation and collection mechanisms, so that rationalize the implementation mechanism of transfer pricing system; (2)the advance of the tax collection and the strengthening in information management systems can make up for the lack of transfer pricing system, while the reform of the system entities can be more effective in the use of existing information to form a normal transaction prices. Therefore, in order to promote consistency in transfer pricing and tax collection mechanisms, we should optimize synthetically the entities contents and procedural contents on the transfer pricing taxation.
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