Transfer Pricing Research Of Marketing Intangible Asset

Under the serious situation of global tax-avoidance, intangible asset becomes the focus of profits transform by transfer pricing. By the perspectives of identifications of transfer pricing, this paper tries to analyses the methods of marketing intangible asset taken by China enterprises and the relative implements taken by China Taxation officials. In the view of the developed countries'successful practices of transfer pricing, especially the loyalty charge, the author studies the problems of transfer pricing audit work in China, such as the lack of evaluation authorities, comparable data and the disadvantages of EPSM. Furthermore, this paper carries out the point that use "evaluate method" to adjust the transfer pricing problem of intangible asset.And bring out the creative innovation and methods of transfer pricing by establishing the comparable data sources, encouraging the intangible asset APA, especially by evaluating intangible asset.