The Supervision Of Multinational Transfer Pricing Research

Along with the carrying out of multinational companies' business in the world, their intra trade is growing rather rapidly, which brings great profit to MNCs. Because transfer pricing contacts closely with intra trade, it causes a lot of attentions. Transfer pricing is a compulsory thing in its own, because if intra trade happens, pricing decided inside will happen too. But the transfer pricing abuse which often happens brings many problems to every country especially to the host countries, such as reducing the tax revenue and unfairly competing. Therefore, to protect those countries' rights, measures must be made to supervise this behavior.The objective of this thesis is the supervision of MNCS transfer pricing, which mainly can be divided into three aspects: the first one is the motives and affects; the second one is the current situations, characteristics and problem; the third one is the suggestions. Based on the above three aspects, this thesis are divided into four chapters:The first chapter includes four sections. The first section analyzes the background and meaning of this thesis; the second section analyzes some basic concepts such as the linked enterprises, arm's lengthen principle, transfer pricing, transfer pricing system, transfer pricing tax system; the third sections recalls the literatures; the fourth sections points out the innovations and weakness of this thesis.The second chapter includes three sections. The first section analyzes current situations and characteristics; the second section analyzes the motives from internal and external perspectives; the third section dialectically analyzes the merits and demerits from three aspects of home country, host country and MNCs.The third chapter includes four sections. The first section analyzes OECD's and UN's supervisions of MNCs' transfer pricing; the section analyzes the supervision of America, Japan ,Canada, China and compares these supervising measures; the third section analyzes the characteristics of these measures; the fourth section analyzes the problems which exist in current supervision.The last chapter includes three sections. In order to direct at the above analysis, this part explain how to enrich the supervision system from three aspects. The first section puts forward some suggestions to international organizations such as strengthen the diversity of the supervision and set up an international coordinating organization; the second section put forward some suggestions to countries, such as strengthen international cooperation and comply with the regulations of international organizations; the third section put forward some suggestions to MNCs such as comply the domestic and international related laws and cooperate with international organizations and related countries.The innovative points of this thesis lie in the following three aspects: the first aspect is that the author uses the method of vertical and horizontal comparing; the second aspect is that the author analyzes the effects of transfer pricing dialectically but not unilaterally; the third aspect is that the author puts forward some new suggestions to supervise transfer pricing.After analyzing the above questions, the author of this thesis hope people can understand transfer pricing more clearly and contribute to the supervision theory and system.