A Study On Tax Avoidance And Adjustment In The Transfer Pricing Of Intangible Assets In Multinational

Transfer pricing is currently a hot topic of international taxation, and one ofimportant issues faced by multinational and tax authorities. In this paper, by analyzingthe nature of intangible assets, the characteristics of the transaction in the form ofintangible assets and Cost sharing agreement theory, pointing out the advantages ofCost sharing agreement in handling tangible assets transfer pricing issues, discussingthe participants invest cash, labor, equity and assets in Cost sharing agreement whenmeasured the contribution of each participants, and raised several issues that should binoted when the participant contribute assets to the intangible Cost sharingagreement.——the ownership of the asset when the Cost sharing agreementterminated, the asset depreciation or amortization, the measure of the value of asset aswell as whether the asset participate in other economic activities when the asset is putinto Cost sharing agreement. And contrasting through real options on stock, intangibleassets investment in kind options, real options on Cost sharing agreement,introduction of the real option method to measure the value of intangible asset in theclass of intangible asserts Cost sharing agreement, evaluating the real options law inregard to the advantages of the traditional method of intangible assets’ valuation aswell as the problems to which should pay attention when use real options method toassess the value of intangible assets. At last, concluding with a summary of theproblems in the intangible assets transfer pricing policy in our country, and proposedto focus on expanding the intangible asset cost sharing agreement rules, in order toimprove China’s intangible assets transfer pricing policy, hoping help tax authoritiesto measure the contribution of participate scientifically in the management of Costsharing agreement for Special Tax Adjustments.