Comparative Study On Marketing Intangibles Transfer Pricing Taxation System

With development of globalization, Multinational Enterprises (MNEs) find outthe great potential of emerging markets and set up a number of subsidiaries in thesemarkets (local subsidiary). In order to gain market share and make customers in thelocal market be familiar with MNE’s goods, the local subsidiary is often granted touse MNE’s intangibles (such as trade mark and customer list) and undertakesmarketing activities in the local market, during which may result in certain“marketing intangibles”. Tax authorities focus on how profits resulting frommarketing activities will be allocated between the local subsidiary and MNE.On a basic description of marketing intangibles transfer pricing taxation system,this thesis will carry out a comparative study on characteristics of several countriesand Organization for Economic Cooperation and Development (OECD). With thehelp of this comparative study, this thesis tries to figure out feasible solutions, aimedat settling obstacles in forming and developing marketing intangibles transfer pricingtaxation system in China.Introduction briefly talks about background of marketing intangibles transferpricing and purpose of this thesis.Chapter1introduces the definition and influence of marketing intangiblestransfer pricing and basic elements of marketing intangibles transfer pricing taxation system.Chapter2carries out a comparative study on marketing transfer pricing taxationsystem of USA, Japan, India and OECD, which will be helpful to development ofmarketing intangibles transfer pricing taxation system in China.Chapter3introduces the situation of marketing intangibles transfer pricingtaxation system in China, points out the flaws in marketing intangibles transferpricing taxation system in China and figures out solutions to settle such flaws.