The Study On Tax Planning Of Transfer Pricing About Intangible Assets Of Multinational Enterprises

In the context of the knowledge-economy, company’s ability of creating intangibleassets is conclusive for their core competitiveness and their position in the competingmarket. Economic globalization has encouraged the expansion of global capital market andcapital flows of multinational corporations, and to accelerate the transfer of intangibleassets such as intellectual property rights. Duo to the financial crisis, many governmentssuffered from the budgetary strains which caused increased anti tax avoidanceinvestigation of tax authorities to compete on the international sources of tax revenue. Theestablishment of International Tax Investigations Standard and Inter-State Tax InformationExchange System have brought new challenges to the existing traditional methods of taxplanning of multinational enterprises.In order to realize their global strategic goals and maximize the profits, multinationalenterprises need to actively find more appropriate transfer pricing methods to adjust thecost of the subsidiaries, to transfer the income of each subsidiary’s profits, to minimize thetax, maximize the profit of the entire group and make efforts to reduce the various political,economic and tax planning risks. Thus, in the context of the companies’ motivation ofenhancing their core competitiveness, the increasing pressure of external competition in theindustry and the promoted domestic and international tax policy and administration ofmany countries, it becomes more important to analyze the tax planning issues on transferof intangible assets.This study will discuss on the tax planning theory, analyze the international transferpricing practices, consider the development of intangible asset of multinational enterprise,and summarize the cross-border transfer methods and tax planning methods regarding totransfer of intangible assets as well as the suggests minimizing the tax risks raised fromtransfer of intangibles. It is expected that this study could provide the theoretical basis forthe tax planning of multinational enterprises, practical supports for the enterprises whichhave oversea investment, and make “go global” strategy paying more attention to tax planning, keeping pace with the times and providing some useful advices on Chinesemultinational enterprise’s development and innovation.