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Research On The Regulation Of Intangible Assets Transfer Pricing Tax Law

Posted on:2016-10-09Degree:MasterType:Thesis
Country:ChinaCandidate:X H HanFull Text:PDF
GTID:2206330461499857Subject:Economic Law
Abstract/Summary:PDF Full Text Request
In the background of economic globalization, international tax avoidance is more and more intensified. It has attracted the attention of the world. Intangible transfer pricing is one of the most difficult issues in international taxation. It affects 70 percent of the world trade and multinational corporation. However, there are no clear answers at the moment of the most basic questions, such as: What is the scope of intangible? Who is the owner?What should be the rate of the return? In practice, how to choose the correct transfer pricing methods? At the same time, the Arm’s Length Principle has beaked through the traditional model, which the main task is to select the best pricing method. The economic substance of the transaction is also an important part of the Arm’s Length Principle.Intangibles are typically unique and not easily benchmarked against any arm’s length transactions. It is seriously challenges the theoretical foundation and practical implementation of the principle.This paper mainly contains case analysis, cooperative study, literature analysis and other mothers. In the intensive study of the latest development of the US and OECD intangible transfer pricing system, this paper was written from two aspects: previous questions of intangible transfer pricing and transfer pricing methods. The purpose of this paper is not to comprehensive analysis the intangible transfer pricing tax law system, but to reflect the latest development and difficulty of intangible transfer pricing field. Hope to make valuable reference for our legislature and tax authorities to better regulate the intangible transfer pricing.
Keywords/Search Tags:the Transfer Pricing of Intangible, the Arm’s Length Principle, Associated Enterprise
PDF Full Text Request
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