A Study On The Tax Regulations Of Tranfer Pricing In The United States

In the past twenty years, Chinese economy has been developing at high speed and has maked a big progress in attracting foreign investment. The rapid development of foreign investment enterprises contributes to Chinese economy, especially to export and gaining foreign exchange. However, it also brings negative influence to us. Transfer pricing is one of the negative influences. It is said that almost 50% Multinational Corporation admitted they had adopted transfer pricing when they traded with their subsidiary company. Transfer pricing is a very ubiquitous phenomenon in foreign investment enterprises, and it did badly to our country's economy. Therefore, lawmaking for transfer pricing is very imperious. Being the most developed country in the world, USA is at an advantage in lawmaking for transfer pricing. It is necessary that China use USA experience for reference, improve our country's correlative regulations and law.My thesis includes four parts:Firstly, I introduce the background and cause of the produce of transfer pricing in Multinational Corporation, the motive, method and influence of transfer pricing in Multinational Corporation, and then I analyse the main supervision measures of international society to transfer pricing in Multinational Corporation.Secondly, I review the evolvement of transfer pricing tax system in USA. It can divide into three phases: produce phase, development phase and mature phase.Thirdly, I analyse transfer pricing tax system in USA. It include law frame, main content, base principle, comparable analysis method, adjustment measures and advance pricing agreement, as well as an introduction to an American transfer pricing case.Finally, combining with the fact of transfer pricing lawmaking in China, use American experience for reference, give some advices to enhancement of transfer pricing tax system in China.