The Tax Risk And Precaution Of Royalties Under The Background Of Digital Economy

With the development of digital economy,new business model gradually came into its emerging features.In terms of the nature of the new business model,intangible assets are increasingly involved in everyday economic activities and it is the integration of the value chain of multinational corporations in the global scope.Adopt various means to circumvent tax with maximum profit,Including both intangible assets transfer pricing and abuse of international tax agreement.It is urgent to cope with the mixed international tax problem in the future.The royalties themselves are a special kind of fees.They are more complex in the determination process and difficult to be identified,and they easily lead to tax risks.With the continuous emergence of various business models,it has brought great challenges to the determination and taxation of royalties.The tax system has always been lagging behind,while the formulation of China's tax policy is even slower than the international advanced system.This has brought inconvenience to the tax administration of the tax authorities.China should improve its taxation system and legal provisions on royalties in conjunction with China's national conditions while absorbing advanced international experience.At the same time,as a developing country,China is often at a disadvantage in the relative upward bias of the international taxation system.In order to protect our country's tax benefits as much as possible,this paper has studied in depth the international and domestic taxation system and related experience and practices,and analyzed the related tax risk of royalties according to the type of tax risk.From the analysis of the impact of the digital economy on the collection of franchise fees,a comprehensive analysis of a number of typical cases reveals the existence of taxation risk,foreign-related tax risk,tax collection and management risk,tax law enforcement risk,etc.,and summarizes franchise fees.The taxation of royalties in taxation management faced with risks in legislation and law enforcement,and from the perspective of information asymmetry,analyzed the tax compliance risk of franchise royalties,referenced existing regulations,learned from the advanced experience of international organizations and developed countries,and improved legislation.Various aspects such as information integration,international collaboration and so on have put forward specific countermeasures and suggestions for preventing the tax risk of royalties.