Our Country’s Anti-tax Avoidance Of Transfer Pricing Management Research

China has attracted large amount of foreign direct investment since the reform and opening up.Although these companies have contributed a lot to our country’s economic prosperity and national employment also brought some advanced technology and management experience for our country,but the positive effect is behind the fact that those multinational companies are making use of the differences between national tax system and the loophole of foreign-related tax law to transfer profits, avoid paying tax revenue and erosion the tax base of our country.Since the 1990 s,the management of anti tax avoidance of transfer pricing behaviors has constant developments with a lot of proud achievement.However the current level of management has been difficult to cope with the pressure brought about by the environmental changes caused by the free flow of capital, technology, personnel in the path of globalization.Now the world is aware of this problem, especially the package of tax reform project- BEPS(Base Erosion and Profit Shifting, profits tax Base Erosion and transfer) endorsed by the G20 leaders and promoted by the organization for economic cooperation and development(OECD) highlights the urgency to solve the problem of tax base erosion and shift profits.We need to further the discussion of the original management mode refer to the mature experience of other countries’ transfer pricing management to solve the problem of transfer pricing management in our country and improve the level of transfer pricing management,safeguard the interests of the state of our country.The first part of this article first introduces the background、methods and significance of the research and the current research status at home and abroad and then introduces the related concept of transfer pricing of anti-avoidance management. The second part carried out by the third chapter to the description of the management status of China’s transfer pricing tax avoidance,first of all,describes the the development of the construction of the legal system by a schedule,secondly,this part expounds the existing transfer pricing tax mode and summarizes the appointment pricing implementation from 2005 to 2013.The third part, according to China’s transfer pricing tax administration management status, this paper expounds the problems existing in the current transfer pricing against tax management.The last part mainly puts forward ideas and suggestions based on foreign relatively mature anti-avoidance tax management operation experience,from the aspect of improvements in regulation construction,advance pricing agreements and the management in transfer pricing tax avoidance.