A Study Of Internal Transfer Pricing For Enterprise Groups

With the development of economy, group enterprises arised from the concentration of productivity, technology and resources to meet the requirements of the economies of scale. Under the new economic situation, the modern large-scale enterprise groups showing the characteristics of scale, industrial clusters, industrial diversification and cross-regional. Affiliated enterprises are indpendent with each other, while there are a certain economic interests between them.As an intermediary of contracting parties, the transfer pricing plays a significant role in the benefits of both traders and the group. It is widely used in the enterprise decision-making, cost calculation and performance evaluation, etc. Reviewed prior research results, the research studied the problem of that at present the domestic research of transfer pricing mainly focus on the empirical analysis, namely, the reason for causing the transfer pricing and the proving on how to choose the price, and that the foreign research is focused on the choice of transfer pricing, pricing methods and the pricing model. But the research of transfer pricing on anti-tax avoidance and of achieving the multiple targets of the company by choosing the transfer pricing is needed to be further evaluated.The research proposes the forming mechanism and the management system of internal transfer pricing for group enterprises based on synergy theory, industrial organization theory, financial management theory and supply chain management theory on the third and fourth chapter which is also the core part of the research. The forming mechanism of internal transfer pricing for group enterprises internalmainly includes forming principle, forming factors, forming patterns, forming methods and optimizing adjustment. The management system includes management concept, pricing authority, management authority, the method of treating contradictional price and the measures of corporate manmgement, tax planning, assessment and incentive which are based on the management of internal transfer pricing.The research takes the large-scale coal and electric power enterprise as an example for case study based on the above-mentioned theory. It analyzes the formationg of industry cluster, the condition of industry synergy, the price characteristics of products, the interface of trading, the problems about transfer pricing and the strategy improvement for the Large-scale Coal and Electric Power Enterprises.The improvement of the study which is about the internal transfer pricing for group enterprises has important theoretical significance.