Study On Transfer Pricing Behavior Of Multinational Corporations In China

With the deep development of economic globalization and integration,multinational companies have sprung up rapidly,a large number of emerging,has become the important carrier of economic globalization.Multinational companies in promoting the development of the global economy at the same time,also gradually began to seek to maximize the economic benefits of global strategy's point of view.Since China's accession to the WTO,in order to attract more foreign investment to boost economic development,constantly introduced preferential tax policy,good investment environment have become favored by foreign invested enterprises,especially multinational companies.Multinational companies with sole proprietorship,joint venture,cooperation,investment form in our country,set up branches and factories,at the same time of contribute to the development of Chinese economy,there is a widespread use of transfer pricing for internal trade and transfer behavior of profit.Under the above background,this paper draws on many scholars at home and abroad on the basis of research achievements and relevant theoretical analysis of transfer pricing to conduct a comprehensive system.First explains related concepts of transfer pricing,the basic principle of transfer pricing system and the general situation in our country,the basic concept on the basis of the overall situation of China's current transfer pricing.Then the influence factors of the implementation of transfer pricing,and analyzes the purpose,focus on analysis of the transfer pricing behavior of multinational companies to the negative influence of our country,the preliminary understanding to the dangers of transfer pricing behavior.Then introduce the GSK classic anti-avoidance case,in the scope of business,such as operating and financial conditions have a comprehensive understanding of,analyzes the transfer pricing behavior,mainly from the similar drug pricing from the average price level and means has the characteristics of concealment two aspects analyzes the transfer pricing;From to reduce or avoid the income tax,withholding tax in our country,set up and control market in our country,enhance competitiveness and free to allocate funds,analysis of the rational allocation of resources by the purpose of transfer pricing;Deformed from the local government investment behavior,our country's foreign exchange control risk,China's pharmaceutical industry laws and regulations and so on to analyze its influence factors of transfer pricing.And from the Chinese government and its own point of view,the analysis of the impact of the transfer pricing in order to more comprehensive and deeper understanding of the whole process of the implementation of transfer pricing behavior and tax avoidance.Secondly,from the multinational transfer pricing compliance thinking about how to standardize the behavior of transfer pricing in our country,from the perspective of multinational companies such as glaxosmithkline puts forward three kinds of solution,were at the time of transfer pricing strategy to hold good long-term,careful,three principles of rationality;According to their own situation to carry on the transfer pricing risk assessment and choose the transfer pricing methods.From the perspective of China's tax authorities proposed two solutions,first in to accept the possibility of reasonable tax avoidance,multinational companies and actively advance pricing arrangements for an appointment.Finally put forward the countermeasures from two multinational companies transfer pricing strategies,including for GSK to refine the medicine method and guarantee regulation fall to the ground and in the same period and strengthen related personal data management;For multinational companies from tax avoidance mechanism,tax regulation,improve the system of transfer pricing tax system and other coordinate and strengthen international tax and coordination Angle put forward feasible Suggestions.