Research On Transfer Pricing Tax System Of Multinational Corporations

Under the background of globalization,the international tax avoidance behavior is gradually showing the haracteristics of complexity and concealment which has attached the great the importance to tax authorities of all countries.The transfer pricing of intangible assets has always been an important issue in the field of international taxation,and it is also one of the most difficult problems to solve.At present,there is no clear definition of the scope of the transfer pricing of intangible assets.One of the most difficult problems in regulating the transfer pricing of intangible assets is to determine the adjustment method of transfer pricing.The traditional method lack of comparability,when take the CUPM and RSPM,it is difficult to find comparable objects.lack of relevance between the price and the cost of intangible assets lead to CPM is difficult to apply.According to this,the international organizations and developed countries such as OECD and the United States put forward a comparative profit method,cost sharing agreement and the appointment pricing system as a basis for adjusting the transfer pricing of intangible assets.Chinese tax laws and regulations adjustment following method: CUPM,RSPM,CPM,TNMM,TPSM,CCA and APA,the transfer pricing of intangible assetstax system of our country's has many problems in the two aspects of the substantive rules and procedural rules,such as the lack of systematic,the definition of intangible assets is too formal,adjustment method is too simple,etc.The transfer pricing regulation of intangible assets needs to be further improved.