| With the development of economic globalization,the influence of multinational corporations is gradually increasing,and they become an important force to promote the rapid growth of the world economy.The more frequent related transactions focus more attention on transfer pricing,not only the multinational enterprises themselves,but also the tax bureaus.From the perspective of multinational enterprises,with the growing scale of multinational groups,transfer pricing has an important impact on the price of insider trading.The multinational enterprises on the downstream business needs can be met in the internal.They can retain as much profit as possible in the corporations.From the perspective of the tax bureaus,the transfer pricing has become an important way for some multinational enterprises of China to avoid tax obligations.It may seriously harm the tax rights of our country and destroy the domestic market environment for fair competition.Tax bureaus of China has focused on transfer pricing problem.Although foreign capital plays an important role in promoting the economic development of our country’s indelible.But tax problem of multinational enterprises is intensifying,causes China’s tax revenue loss and affects the long-term development of China’s economy.Despite more than 20 years continuous exploration and research,China’s transfer pricing tax system has considerable development.But compared with developed countries,China’s transfer pricing tax system still exists obvious deficiency.The development of our tax system could not match the rapid development of economy.There are still various problems.For example business relationship standard is not good enough;the taxpayer’s proof responsibility is not reasonable;the overall quality of the anti-avoidance team needs to improve.At present,it is common that multinational enterprises transfer profits in China and tax loss causes many serious problems.It put forward a severe challenge to China’s tax bureaus.It’s time to improve the transfer pricing taxation system.At the time of the BEPS plan signed by the Group of Twenty,China should take the best use of the opportunity to improve the international tax collection and management system in order to cope with the problem of transfer pricing tax avoidance.In this paper,based on the existing research results,use normative analysis,empirical analysis,comparative analysis and other methods to study the current transfer pricing tax system of China.First of all,through the study of the status of China’s transfer pricing for tax avoidance,combined with previous research result,analyze the major methods of transfer pricing tax avoidance of domestic multinational enterprises,the results of tax avoidance in multinational enterprises transfer pricing as well as the tax loss scale in China caused by the transfer pricing Secondly,study the problems of the current transfer pricing tax system in China.Then,this paper analyzes the impact of these problems on the transfer pricing of multinational related enterprises,including the cost of tax avoidance,the efficiency of anti-tax avoidance,the tax avoidance of transfer pricing,tax related information asymmetry and so on.Use game theory to study the game relationship between tax avoidance and tax avoidance of multinational enterprises.Finally,puts forward the measures of the transfer pricing tax system in order to perfect the current system.For instance,perfect the transfer pricing taxation legislation;improve the anti-avoidance work efficiency;improve the advance pricing system;strengthen the anti-tax avoidance of international exchange and cooperation.I hope China’s tax bureaus can improve the efficiency of tax collection so as to solve the problem of high tax compliance costs and high tax administration costs,and promote international cooperation.Through bilateral cooperation and multilateral cooperation,establish and improve the coordination system of international tax services and management.Ultimately,we can effectively prevent the tax avoidance of multinational corporations in China,reduce the tax evasion and protect the national tax revenue. |