Research On Transfer Pricing Tax System Of Intangible Assets

Multi-National Corporation is the product of economic globalization，The fasterand faster economic not only brought rapid economic development but also broughtthe problems of transfer pricing tax avoidance. The transfer pricing problem involvesa multi-stakeholder, which need taxpayers and tax authorities to have aeffective communication and coordination. Many governments gradually payattention to transfer pricing of related enterprise tax legislative work. China’s currentlaws and regulations in this regard is not perfect compared with the USA and OECDwhich have experience in transfer pricing. We need to learn experience from them.Intangible assets has its own characteristics which lead enterprise’s intangibleassets transfer pricing tax avoidance is more concealed compared with other assets.According to the survey, intangible assets value in the enterprise asset’s proportion isrising and the transaction of intangible asset’s proportion increased continuously ininternational transactions. For the time being, both in theory and practice circles arevery concerned about this issue. The OECD held a meeting in2013to discuss themodification and perfection of the transfer pricing of intangible assets rule and formeda revised draft. The conference put the improving intangible assets transfer pricingtax work into the 《solve the base erosion and profit shifting》.This paper starts from the basic theory of intangible assets and transferpricing,from the shallower to the deeper, Introducing the situation of intangibleassets transfer pricing tax system and analyzing the existing problems. Here is notonly the theoretical analysis will be introduced into the analysis but also introducesome actual cases to reveal problems. The tax administration of transfer pricing in ourcountry started later than the America and OECD, We should in light of ourown national conditions and learn from their experience. On the valuation ofintangible assets, taking into account the income present value method having manydefects, I attempt to use the real option valuation of intangible assets.