BEPS Transfer Pricing Tax System Research Under The Background Of Intangible Assets

In recent years, multinational companies through transfer pricing to shift profits is getting worse, it has seriously affected the tax benefit individual countries.Intangible assets as an important factor in economic development in the 21 st century, more and more attention in various countries, but because of its own characteristics so that multinational corporations in the transfer pricing is more popular to use intangible transfer of profits.Value only legal form and ignore the economic substance of the traditional transfer pricing rules increasingly being questioned various aspects of the world.The traditional transfer pricing rules on the definition of intangible assets is unclear, unclear ownership, transfer pricing considerations is not perfect question in this action plan have been definitively settled.OECD trying to build a new transfer pricing rules to solve real problems encountered intangible transfer pricing, but the provisions still exist imperfections, which need to be resolved in the future.China as the world economy, a very important development in recent years very rapidly.But the statute as a traditional country, the progress of laws and regulations to modify the speed of economic development can not keep up, so intangible transfer pricing cases occur in real life there is no clear guidance on the appropriate regulations for the enforcement of the tax authorities and taxpayers comply bring a great deal of legal uncertainty.In view of this, China’s national conditions should combine to absorb the beneficial results of the action plan to continuously improve relevant laws and regulations in China.This article is based on this, combined with a typical case of intangible assets on the domestic transfer pricing, to inadequate legislation and practice of appearing analyzed, and absorb and draw BEPS the latest results on the basis of our laws made perfect related reasonable proposals, thereby hoping to provide a useful reference for the improvement of intangible transfer pricing.