Multinational Transfer Pricing Issues Discussed

With the trend of economy globalization, TNC take the more and more important status in the global economy. Faced to the increasing group, there are series of problems on it. In all the problems on TNC, TNC 's managers and the governments have focused on the problem of transfer pricing. The TNC's managers hope to achieve the strategies through the transfer pricing. And the governments hope to restrict TNC's transfer pricing with regulation, law and so on, and can recover the loss of taxation and protect the benefit of countries.The theme began with the definitions, characters, theories and the related corporation of transfer pricing and discussed the basis that the transfer pricing occurred. Then it illustrates the method of transfer pricing, and importantly discussed with purchases or sales of goods and intangible assets.According to different comparisons of purchases or sales of goods, it can be divided into comparable transaction method and comparable profit method and analysed further classically. Because of the specialty of the pricing method of intangible assets,difficult to find a comparable transaction, the pricing method is different from the purchases or sales of goods. And discussed separately.Following this, it analysed the strategies on taxation and non-taxation and illustrated the different strategies on different objects by TNC through the cases. And discussed the future of it. But the action of transfer pricing is aimed to escape the government regulation and taxation. Its negative effect decided that it will be punished by all the countries, so all the countries pressed the law to restrict the transfer pricing. In accordance with the transfer pricing used by TNC, all the Taxation Bureaus can adapt it and punish the TNC. With the globlization and variety of TNC's operation,old management methods have out-style and can be not satisfied with necessity. Now many countries transfer the backword adaption into forword adaption.As far as China is said, the laws of restricting transfer pricing and related people are not satisfied and have many shortcomings. We should compare with the laws of the developed countries, according to China's situation, to press the related laws. China' Taxation Bureau took action on the TNC's transfer pricing and enforced defence of the TNC's transfer pricing from the laws, the related people and account. Be stricted with the TNC's transfer pricing and defend escaping taxation and transfer profit.