Research On Taxation Of Transfer Pricing Of Intangible Assets Under BEPS Action Plan

In recent years,multinational companies through the transfer pricing tax avoidance phenomenon are more serious,resulting in loss of governments' tax sovereignty.In the 21 st century,a new mode of economic rapid development,intangible assets,as an important factor to promote the development of economy,more and more attention from all countries,but as a result of its own particularity also become the object of multinational enterprises in favor of transfer pricing.Traditional anti-avoidance measures have been unable to resolve the reality with intangible assets transfer pricing tax issues,OCED through BEPS action plan to build a more reasonable transfer pricing rules for intangible assets transfer pricing tax base erosion caused by the transfer problem and profits.China occupies an important position in the modern economy,more should be combined with national conditions,according to the characteristics of wireless assets,in the BEPS action plan under the background of intangible assets in the current tax system of transfer pricing leak fill a vacancy,in order to better adapt to the trend of internationalization.Through theoretical and empirical analysis,this paper draws the intangible asset transfer pricing as a multinational enterprise main tax measures to have the better under the development of new business model,the traditional tax rules to deal with difficulties.Under BEPS intangible assets transfer pricing tax system in our country,still need to constantly improve and perfect Suggestions based on the intangible assets.