The Study Of Legal Regulation Of Transfer Pricing

With the rapid advance of economic globalization and the accelerated development of China's market economy, increasing number of multinational companies to invest in China, especially after China's accession to the World Trade Organization, multinational corporations into China's domestic market. At the same time, the strength of domestic enterprises to actively go out and expand their business globally. Multinational corporations promote economic development in China, at the same time, more and more companies use transfer pricing to avoid Tax obligations. This behavior has seriously damaged the interests of China's tax revenue and deviates from the taxpayers tax fairness, disrupts the normal rights of international taxation of income distribution. To safeguard the interests of national revenue and protect the safety of the state's tax,Transfer pricing of associated enterprises to promote the prevention and adjustment research and improve the legal regulation of transfer pricing system has become an important theoretical topic of tax law in the process of the urgent requirements of the rule of law.Legal regulation of transfer pricing system is to contain and prevent the implementation of related enterprises through transfer pricing, to adjust and regulate the conduct basic tax law system between associated enterprises. At present, about the affiliate transfer pricing, transfer pricing of associated enterprises of the legal regulation is still in its infancy, China's relevant laws and regulations with a wide gap between the more developed countries, in large part need to be further improved. Therefore, this paper based on our domestic system of legal regulation of transfer pricing related research, through transfer pricing law the most mature and perfect American studies, while covering Germany, Japan and other developed countries on transfer pricing legal regulation system, and describes the relevant international provisions, Through comprehensive analysis, providing a useful reference system for our current legal regulation of transfer pricing.This paper illustrates specific transfer pricing analysis firstly and describes the meaning of transfer pricing, motivation and the need for legal regulation. On this basis, article discusses the legal regulation of the transfer pricing principle with the relationship between the substantive principles and the statutory tax, laiding the theoretical basis of legal regulation and explains the main transfer pricing, the basic principle sand methods. Paper then describes the legal regulation of foreign transfer pricing system, focusing on the Legal Regulation of Transfer Pricing in the United States, which is the most perfect law and comprehensive law. In addition, Paper analysis Germany, Japan, international economic cooperation organizations relevant laws and regulations,Laiding the legal regulation of transfer pricing reference base. Finally, the paper describes the legal regulation of transfer pricing system, and points out the system of legal regulation of transfer pricing problems, and proposed a sound recommendation based on the relevant foreign and international law...