Research On The Anti Tax Avoidance Of Multi-National Corporation Transfer Pricing With FLP Company As An Example

In the tide of economic globalization, Multi-National Corporation through worldwide investment, production, sales and other business activities, which greatly promoted development of the global economy. With development of Multi-National Corporation also had the problem of transfer pricing. On one hand, as a Multi-National Corporation internal transactions important price mechanism, transfer pricing for the Multi-National Corporation brought hitherto unknown interests; but on the other hand, because it has become the necessary means of Multi-National Corporation international tax avoidance, destroyed the order of Taxation, the influence of various host tax income. Therefore, the transfer pricing issues have become the international taxation theory and practice circles concern.This text is from our country government and taxation departments management point of view, the research Multi-National Corporation transfer pricing tax issues. First of all, to introduce Multi-National Corporation transfer pricing of the related research at home and abroad, and gives a review, this paper raises the research background and significance. Secondly, on the Multi-National Corporation’s related concept, analysis of Multi-National Corporation transfer pricing of the related theoretical basis and motive. Once again, the Multi-National Corporation transfer pricing tax status and negative effect are studied, so as to put forward some of the transfer pricing tax regulation measures to provide a theoretical reference. Then, through the tax practice in the FLP case analysis, in order to better understand the Multi-National Corporation’s transfer pricing and tax control function. Finally, in summary our country implementation of transfer pricing tax system since the practice and learning from international successful experience, put forward to perfect the transfer pricing tax system of our country and the countermeasures.