Research On The Difficulties Of Customs Royalty Audit

In recent years,transnational corporations from the developed countries as the main trade organizers and promoters,won a majority interest in tax competition in developing countries by their dominance of rule making and technical advantages.It attracted the attention from all over the world.BEPS(Base Erosion and Profit Shiftingr)action plan is the project that G20 and OECD work together to promote the reform of the international tax system under this backgroud,the purpose is to establish a more equitable distribution of tax sources.The 8-10 action plan of the project ensure the core principles is "Aligning Transfer Pricing Outcomes with Value Creation",which match the requirements of multinational group members should according to their own in the development of intangible assets,value promotion,maintenance,protection and utilization of the performance of the functions in the process,investment and risk to determine their contribution to the the value of intangible assets,which determine their respective shall enjoy the benefits.At the same time,the customs as a tax administration organ in parallel with tax authorities and financial departments,one of the key and difficult technology trade supervision is the approval process of import and export goods duty paid price for royalties valuation.As an important means of follow-up supervision,customs audit plays an irreplaceable role in relieving the pressure of customs clearance,expanding the time and space of supervision,and guiding the self-management of multinational enterprises.But at the present stage,the customs royalty audit is faced with the difficulty of finding,identifying,sharing,investing,and difficult to unify.How to solve the plight becomes an important problem.Based on the basic theory and the status quo of customs royalty audit,adopting the research method of literature references and case of photography with the comprehensive use the relevant provisions of the transfer pricing of intangible assets under BEPS,this paper analyzed how to solve the plight of customs royalty audit.At the same time,based on the J company's franchise fees for audit case,this paper carried out a detailed analysis of the specific case,which proved the feasibility and the high quality and efficiency.Then it make a certain contribution on how to improve the performance of customs aduit,and how to control the risk of the law enforcement and corruption.