Research On Transfer Pricing Tax Risk Management Of Q Co.Ltd

With increasingly serious problem of multinational companies transfer pricing tax avoidance, tax authorities of countries have increased transfer pricing management efforts. Affected by the international anti-avoidance environment, our anti-avoidance situation is heating up:on the one hand, the State Administration of Taxation has issued many files to perfect the tax system of transfer pricing, regulate the anti-avoidance operation process and improve the efficiency of anti-avoidance work; on the other hand, China has taken part in the "BEPS action plan" OECD advocated,further join the international anti-avoidance cooperation and learn from the results of the action plan to modify the current tax policy, so that enterprises using trankfer pricing to avoid tax in China are facing more serious tax risk, in particular those ones tax authorities has focused on.Q co.Ltd is indirect invested by Taiwan-funded enterprise A Group through foreign offshore companies in the mainland, mainly produce plastic packaging, is only responsible for manufacturing, the risk of a single function, raw material procurement and product sales are controlled by the parent company, has a high percentage of related transactions, has business dealings with enterprises in tax havens,and its tax indices are abnormal, conform to many features tax authorities focus on in transfer pricing investigation. As a single function-risk manufacturing model, transfer pricing tax risk the Q co.Ltd facing has certain representativeness, representative and comprehensive, its tax risk identification, assessment and response method has reference value for other similar enterprises. This paper first introduced Q co.Ltd background and related transactions in detail, and then from the transfer pricing tax environment change, Q co.Ltd tax index analysis and specific connection transaction tax risk identification in three angles, found its tangible assets associated sales tax and royalty payment, and then through function-risk analysis, choice of transfer pricing method, comparison analysis to evaluate the tax risk, it is concluded that the sales profit margin is significantly lower than the comparable companies, the tax risk, and puts forward the reasonable adjustment of transfer pricing methods, related transaction contract review and revision, optimize enterprise value chain and business process, fully prepared pricing compliance evidence information and apply for APA agreement. Finally summarize the advice of transfer pricing tax risk management, which fully grasp the dynamic transfer pricing tax environment, establishing the transfer pricing tax risk identification and assessment mechanism, timely adjust transfer pricing method and pricing according to the actual need to apply for an APA agreement.