Research On The Supply Chain Model Of The Transfer Pricing Of Multinational Enterprise

With the development trend of economic globalization,multinational corporations have become an important part of the world economy.Among the various means that multinational companies take in order to achieve supply chain configuration optimization and after-tax profits maximization,transfer pricing is an important measure.Today,through transfer pricing approach,more and more multinational companies have transferred profits from high-tax areas to low-tax areas for tax arbitrage,and obtained a greater after-tax profit in the supply chain.Against this background,the paper is to study the selection of supply chain model during the internal transfer pricing process of multinational companies.The paper focuses on the selection of the models for manufacturers and Distributor,which are nodes in the supply chain during the process for multinational companies' implementation of transfer pricing to maximize after-tax profits in the supply chain.From the two aspects of tax accounting and supply chain design,consider the definition and boundary of transfer pricing,tax and non-tax motivations,principles that should be followed(the principle of fair trade,etc.),and the methods that can be taken for transfer(cost-plus method,profit distribution method,etc.).And then it combines with actual case studies of multinational corporations,and analyzes the unique models of manufacturers and distributors in the transfer pricing process.According to the functions and degree of risk performed by the manufacturer and distributor,divided the manufacturers into Toll Manufacturer,Contract Manufacturer and Full-Fledged Manufacturer,and divided the distributor into Commissionaire,Limited-Risk Distributor and Full-Fledged Distributor.Taking the selection from three models of manufacturers and distributors into account,the paper establishes the transfer pricing model,and solves it with logistics planning software CPLEX.The model considers the impacts of the tax model,the market environment,supply chain operation costs,risks and other factors,and constraints such as market quotas,material conservation,and internal transfer pricing restrictions.Finally,after analyzing the results,Base on Supply chain profit maximization,The effect of tax rate on the supply chain model is reflected in the difference between the income tax rate increases or the tariff rate decreases,the manufacturer and distributor model selection is more biased in the multi-function,high risk model;The impact of the market on the supply chain is reflected in the lower tax rate when the market size is larger or the market is more stable,manufacturers and distributors model selection is more biased in the multi-function,high risk models.