Tax Risk Analysis On Intangible Transfer Pricing Of HL Multinational

With the advent of economic globalization and the deepening of the knowledge economy,Intangible assets become the core competitiveness of multinational of related party transactions involving intangible assets increased to prevent the use of multinational intangible transfer pricing tax avoidance has become not including China difficulties national tax authorities less the focus of attention and work. Establish and improve the country’s intangible transfer pricing,not only help to further improve the quality of anti-avoidance and safeguard our country’s tax sovereignty, and is building an innovative country and the inevitable choice for China’s international tax competitiveness, such studies for tax substantive work and theoretical study has important significance. And tangible assets, compared with a value of intangible assets is difficult to assess, and easy to transfer ownership of the characteristics of traditional ownership by legal and economic analysis to determine the ownership of intangible assets related to profits attributable, we can not effectively solve the multinational use of intangible assets to erosion the tax base, as well as between countries in terms of the determination of intangible assets related to profit attributable to the presence of more and more controversial. This article aims to analyze writing HL multinational intangible transfer pricing methods of tax avoidance risk analysis and make recommendations, use case analysis, data analysis and comparative analysis of HL multinational elaborate, drawn suffered multinational risk HL give recommendations.This paper is divided into the following chapters are discussed:The first chapter is to introduce the basic situation of multinational HL and related transactions, to understand the background and related transactions HL multinationals, organizational framework, intangible content.The second chapter of the related business transactions HL multinationals current transfer pricing methods, these intangible assets related to business transactions, by decree law legally relevant international tax basis, from price-based adjustment method of analysis to profit several aspects of basic adjustment method analysis were carried out a detailed analysis of HL multinational transfer of intangible assets.The third chapter analyzes the HL multinational tax risk related to intangible assets subject to transfer, for example under tax audit risk, production and management aspects of the subject of tax risk and research in the tax base erosion and profit transfer outcomes based on global value chains and market premium theory HL multinational intangible transfer pricing tax risk analysis.The fourth chapter, according to the above problem, the following countermeasures: Countermeasures for HL multinational intangible transfer pricing hazards preparedness, including the establishment of a clear tax tax management team, strengthen the use of APAs and so on. For HL multinationals against future tax collection and international transfer of intangible assets in China the right to change the pricing policy changes brought about by the tax risk.