Study On The Tax Management Of Transfer Pricing In China

With the development of global economic integration, multinational group using loopholes in the differences in national tax system, tax collection and management, as well as international tax rules of lag and lack by eroding the tax base of the country, continue to shift profits, hidden income to without or almost without economic substance of low tax or tax exemption country(region), caused widespread concern in the world. In 2012, the group of 20 commissioned the organization for economic cooperation and development to carry out the tax base erosion and profit transfer action plan, in September 2013 at the G20 summit in St. Petersburg get leaders signed through. After the G20 summit, the fight against international tax evasion has been an important issue for all countries, the world rise of a wave of anti-tax avoidance. Countries around the world continue to deepen international cooperation, actively participate in BEPS action projects, increase the transfer pricing, international tax collection and other areas of cooperation and cooperation in the field of cooperation, the multinational global tax avoidance behavior zero tolerance. In recent years, China will continue in the field of politics, economy and tax strengthen international cooperation, actively participate in formulation of new international tax rules, establish the concept of tax powers, increasing China's international influence and the right to speak. But we should still be aware that the current transfer pricing management is still to be improved, especially the transfer of pricing management between domestic and foreign enterprises need to be further strengthened.In the organizational structure, this thesis consists of six chapters. The first chapter describes the research background, significance, literature review, research content and methods, innovation and deficiencies. The second chapter briefly introduces the basic concept of transfer pricing, the identification standard of affiliated enterprises, the achievements of the relevant enterprises and the prevention and control system of anti-tax avoidance in China. The third chapter analyzes the present situation of the transfer pricing of enterprises in our country from three aspects of foreign investment, "going out", and the related enterprises, which lays the foundation for the study of the optimal transfer pricing management. The fourth chapter lists the typical transfer pricing tax avoidance case analysis, so that we have a more profound understanding of the general existence of the transfer pricing behavior. The fifth chapter makes a comparative study on the transfer pricing management of the United States, Britain, India, Brazil, and further analyzes the development trend of transfer pricing under the new international tax rules system. The sixth chapter puts forward suggestions on how to perfect the transfer pricing management in China from the aspects of the system environment, the international cooperation, the establishment of talents and the construction of information.