Analysis On The Tax Avoidance Of Transfer Pricing Of Intangible Assets In Company H

With the deepening of world economic integration,international tax issues appear.Multinational companies have the characteristics of global operations,its business scope around the world,which for its intra-group transactions to achieve the purpose of tax avoidance to provide objective conditions.The current multinational corporations usually use the intra-group transaction transfer pricing to carry out international tax avoidance,this tax avoidance is the weak part of China's tax authorities in the past,especially the current tax avoidance within the group and the transfer of intangible assets pricing.Intangible assets become the main driver of business development and directly enhance the enterprise's value with economic development and technological progress.Transactions of intangible assets within multinational groups have been increasingly frequent and diversified and complex.Due to the existence of differences in national tax rates and the tax system,multinational corporations generally use transfer pricing of intangible assets in the global in order to seek international tax avoidance.Internet economy and the advent of the era of knowledge economy,making intangible assets become an important part of business activities,intangible assets can make corporate value soared rapidly,multinational corporations within the intangible assets of the transaction more and more frequent forms are more and more diverse The At the same time,there are differences in all aspects of the enterprise income tax law based on the actual situation of the country,which provides a window for multinational enterprises to carry out pricing and avoidance of intangible assets in the world.Intangible assets are different from tangible assets.The determined value is often difficult to quantify,when especially the transactions occur in intra groups.This chesis take H company for instance to analysis and research transfer pricing of intangible assets in the global in order to seek international tax avoidance,Then using comparative analysis of the adjustment cases,discuss the objectivity of adjustment results to explore new ideas and methodswhichapply to the transfer pricing of intangible assets;finally combining with the transfer pricing provision about intangible assets in our legislation,put forward improving countermeasures.OECD trying to build a new transfer pricing rules to solve real problems encountered intangible transfer pricing.