Related Party Transactions To Transfer Pricing Issues

In the related party transaction problems of transfer pricing that earliest attract people's attention are appearances of multinational corporation. The multinational corporations rely on their superiority of transnational production and sales, dodging or reducing tax burden using the related party transaction method to seek the maximization of profit and improper income. As a result of uncertainty of related party transaction as well as the unfairness, hiding, and difficulty of supervision and management, damaging interests of the investors and the nation. Because of it's nimbleness, transfer pricing becomes the core problem of related party transaction. Through the pricing policy, the information user can judge the fairness and justness of the related party transaction, as well as the influence on the corporate finance condition and operating results, preventing the listed company to violate general investors' benefits by the related party transaction or false transaction and guarding multinational corporation to internationally carry on avoidance of taxation.With our country opening to the world unceasingly and expansion, specially our country joins WTO, our country economically makes swift and violent development, the transnational investment increases day by day. The phenomenon becomes more and more serious that the foreign investment enterprises through affiliated enterprise's service intercourse make use of transfer pricing to shift profit and dodge the tax revenue, which not only corrode financial revenue, harm country rights and interests, but also has created the pseudomorph which the investment enterprises lose money, and so on negative effect, if containing not effectively, no matter what it continued to spread, it can fundamentally vacillate the tax base, destruct fair tax burden principle, adverse to the expansion to open, attract foreign capital. At the same time, with the enterprise group increasing unceasingly, the transfer pricing already was not merely an international tax revenue question, having such similar problem in the domestic mother and child company and the total score company. The enterprise group using the related party transaction transfer pricing plaster financial report, shift the fund and the profit of listed corporation, which a phenomenon focuses attention on the stock market.This article begins with the related party transaction concept, on the base of systematic analysis of the related party transaction transfer pricing the various countries as well as the OECD. It analysises present situation of the related party transaction transfer pricing, discover the problems, especially in the tax system and the information disclosure, proposes improvement measure and the suggestion to how to disclose information, avoid the finance operation, strengthen the audit of transfer pricing policy, consummate our country's transfer pricing unceasingly, protect the young investors' rights and interests, strengthen transaction supervision and management, in favor of the solution to the related party transaction transfer pricing problem of various countries and our country in the international economy contact question, in favor of the maintenance of legitimate rights and interests of country, finally promoting the cross normally international economy communication. This article is divided three parts.The first part introduces general concept of the related party and the transfer pricing, the character and the methods of the transfer pricing, simply elaborates the motive of the related party transaction transfer pricing and the corporate finance condition and the tax payment influence; The second part introduces international accountant standard and our country accountants standard connected the present situation and the existent problem of the related party transaction transfer pricing, and elaborates present tax laws in transfer pricing management of our country; The third part proposes suggestions to consummate transfer pricing, including pricing policy, accountant standards, tax system and supervising and managing system consummation.