Transfer Pricing Study

There have been issues about international dodging tax since the organization of transnational cooperation coming into being. Transfer pricing has been one of most important method of dodging tax. And it comes to be the focus of domestic and international legislation and supervision. The adjustment of the special tax (Trial) made by the State Administration of Taxation responses the achievement of researchers. This article based on the adjustment aims at the further research about issue of the transfer pricing, for the purpose of perfecting the adjustments.The first part of the article is mainly about the illustration of the basic theory of the transfer pricing. There are analyses about the motivation of the transfer pricing, the forms and the influence of the transfer pricing, and the other items we should pay more attention about the motivation of the transfer pricing. Besides, the first article still introduces the introduction of the new tendency, mainly including the new development from the influence from E-business, globalization and the government intervention to the transfer pricing.The second part of article tries to analyze the international development condition of transfer pricing, and introduce the summary of the tax regulation of OECD, American and Japanese, on the contrast of the tendency of china, and the necessity of international cooperation on the issue of transfer pricing.The third part of article makes the further introduction of the new mechanism of the adjustment of the special tax (Trial) after the illustration about the general situation, such as advanced pricing agreements,the preparation mechanism of the files of the same period. And there are some positive influences for the regulation of the transfer pricing, as well as the potential deficiencies.The fourth part of article tries to give some advices for the improvement of the tax regulation of the transfer pricing, including the mechanism of advanced pricing agreements, the legislation of the transfer of intangibles, basing on the above illustration about the issue.