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The Study On The Transfer Pricing Methods And Taxation Of Johnson Corporate

Posted on:2009-05-15Degree:MasterType:Thesis
Country:ChinaCandidate:H K ZhuFull Text:PDF
GTID:2189360272478454Subject:Business Administration
Abstract/Summary:PDF Full Text Request
In recent years, there are some survey reporting have been presented by PWC, Earnest & Young, Deloitte and KPMG Peat Marwick, Taxation strategic planning is the first motivation to the tax scheduling. Multinational Company Corporate they have studied and followed Taxation Policy closely. Multinational Company pursues maximum profit that always accompany with transfer pricing, so, it is no doubt that multinationals' transfer pricing strategy and its applications are becomes hotter topic all over the world.Form corporate point of view; it is associated with best performance stratagem to be tie with minimized taxes costing. When company decides products selling price, which are base on company sales goal, profit target and market share so on.The study is focus on transfer pricing defined between inter - company transaction within group or corporate. Due to local government performance appraisal are almost base on "GDP" and taxation amount. Therefore, even no fluency to all over China, but there are still have unbalance between different areas, it was bring up lots difficult to those company who want to implement transfer pricing. Therefore, to reach transfer-pricing agreement between local tax governments would be a tendency for long time, the best way for the company to decrease reasonable tax cost by using transfer-pricing agreement.Transfer pricing to the regional tax competition by detailing the affiliated transactions of the enterprises located. The most difficult lay on tax regulation and comparing the preferential fiscal and tax policies in some different regions.This article is adopted JOHNSON Corporate Transfer Pricing Agreement making. In relation to the Johnson's products sold in China Market and Manufacturers sold directly to customers. Going forward, the Group intends to implement a trading model in China by having centrally buying from the Manufacturers and selling in the Chinese domestic market. With respect to the new trading model in China, need a Transfer Pricing study to evaluate the risk from China transfer perspective. The functional analysis indicator that going forward under the new model will become the Principal Trading Company bearing most of the business and entrepreneurial risks associated withthe market.Based on analysis, which will has detail and address this paper. The redistributionof profits is consistent with shift of risks from Manufacturer; it will assure a fixedmark-up on their cost.Therefore, it is necessary to have transfer-pricing agreement between internal-companies, so that it could be optimized profit and minimized tax cost by reforming the business sales model changed. This may be designed to re-allocate tax revenue among headquarter and subsidiary company. As a result, major taxes will be established properly at all fiscal levels with the high efficiency of the revenue sharing system.Tax perspective, with the conducting of the taxation policy of China, to thosemultiple company, in terms of the strategic tax decision becomes, the article points outthat a firm would chose tax methods based on tax-oriented considerations to maximizeits profit.
Keywords/Search Tags:Transfer pricing, Transfer-pricing agreement, Tax competition, Associated trading between internal company
PDF Full Text Request
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