Development Of Transfer Pricing System For Multinational Enterprises According To OECD Guidelines

Along with the breadth and depth of economic exchanges between multinational enterprises were strengthened, the weight of inter-company transactions become higher accordingly in multinational enterprises, and also the importance was strengthened. For multinational enterprises, inter-company transactions can help them to realize economies of scale, profit maximization; and as the transfer prices which are lubricants of inter-company transactions, its importance become more and more obvious. But it is obvious that the environment of multinational trades are complicated and change from country to country, and the tax policies of different countries are obvious different; so it become challenges for multinational enterprises on how to establish transfer pricing system to get the "optimal transfer price" and can achieve group goals to the maximum extent with the support of such system. This study will mainly focus on this problem and try to solve it.According to current domestic and overseas researches, they already focused more attention on the purpose and function of transfer price, the influence on tax policy, transfer pricing method, transfer pricing model. But such researches either only focused on the qualitative analysis of purpose and function of transfer prices, the influence on tax income, or only focused on quantitative analysis of transfer pricing economy model, the mathematical programming model; but hardly made the combined analysis of tax policy, transfer pricing method and mathematical programming model by actual case analysis. This study attempt to use case study analysis, to select transfer pricing method based on OECD guidelines from a point of view of a company, and try to realize the targets (tax minimum, profit maximum, etc.) of the group company at the most extent, and finally get the optimal transfer price via established transfer pricing system.