Instance Of Company A Of The Transfer Pricing Of Multinational Corporations

In current years, Chinese tax authority has realized that a large number of tax has been lost by the arrangement of the related parties transaction among the Multinational Enterprises (MNEs). Therefore the tax authority in China has enhanced the supervision on the related party transaction strongly. Facing the trend of more severe supervision on the related party transaction by the tax authority, the MNEs should plan their related party transaction carefully to comply with the Chinese taxation law so as to avoid the risk of tax audit or the risk of transfer pricing adjustment accordingly.The paper does much research on the transfer pricing theory and taxation practice in the foreign countries and China. Based on the above research, the paper does demonstration analysis about transfer pricing for a MNE as well. These research and analysis will be very useful for assessing the transfer pricing risk and the related party transaction planning for a MNE in China.All the research is done by combination of the theory research and application analysis, by combination of qualitative research and quantitative research, by combination of comparison study and system analysis, The paper contains the following content: (1) the theory research on transfer pricing, which includes the research on the transfer pricing rules and methods made by the Organization For Economic Co-operation And Development and China. (2) demonstration analysis on the related party transaction of Company A, which includes the profile study of the related party transaction of Company A, the function and risk analysis on the associated enterprises involved in the transaction, selection of the proper transfer pricing method and comparable companies, qualitative and quantitative analysis and assessment of the transfer pricing risk for Company A and the policy suggestion on the transfer pricing for Company A. (3) based on the above theory and demonstration research, making suggestion on the transfer pricing policy for the MNEs in China.