The Tax Risk Management Of Transfer Pricing Between Affiliated Enterprises

With the development of economic globalization, more and more multinationalcompanies begin to seek from the perspective of the global strategy in order to maximize thebenefits, One commonly used method to transfer profits between multinational companies istransfer pricing. Transfer pricing resulted in the loss of the potential benefits of variouscountries, thus countries have introduced anti-avoidance legislation to combat. Once theenterprise encounters the transfer pricing tax anti avoidance survey, the risks involvedincluding not only impose a punitive interest payments, double taxation, but also relate to theobjective environment punishment such as regulatory aggravated. As the enterprise taxationrisk is increasing, so it is necessary to analysis the formation of the taxation risk and carry onthe effective risk management.This article combines with specific anti tax avoidance case. Through the analysis ofsome relevant indexes of enterprise process, it discovers the reason why the company isidentified to use the method of transfer pricing to tax avoidance.The following part is basedon the big enterprise tax risk management guidelines and “the second file”from the nationaltax bureau,c combined with risk management theory,points out the enterprise risk. revention,using the risk management theory,pointed out enterprises’ negligence in the risk identificationand prevention.The article’s analysis towards X company is based on the conditions ofproduction and management， enterprise strategty mangemetnt, enterprise risk ratio,contemporaneous documentation preparation. Then according to the risk control theory, itput forward corresponding countermeasures.The article mentioned advance pricingarrangement to prevent risk. Finally we hope the actual case can play a certain role to preventthe enterprise risk in related transactions.