| In today’s world,the process of globalization is in-depth;cooperation in economic,political,and military affairs between the countries of the world is also becoming increasingly close.Since the Party Central Committee proposed the "One Belt,One Road" initiative in 2013,China’s economic and trade cooperation with the world has become more frequent and deeper.The international engineering contracting and construction industry has also attracted many Chinese engineering groups and enterprises,but companies that go abroad are not only facing economic and political risks,but also need to overcome cultural differences and tax risks.Foreign contracted engineering enterprises are faced with tremendous development opportunities under the “Belt and Road” initiative,but they also face many risks and challenges,reducing project cost,shortening the construction period,ensuring the quality of project projects and reducing the risk of owners are every foreign contracted project.Enterprises need to focus on solving problems.Transfer pricing tax planning is a tax planning method commonly used by foreign contracted engineering enterprises.This method has the characteristics of diversification,easy operation and obvious tax avoidance effect,so it has become a mainstream tax planning choice.However,transfer pricing tax planning may exhibit different characteristics in different companies,and different principles and strategies need to be grasped.Therefore,it is very necessary to deepen the foreign industry contracting transfer pricing tax planning strategy to provide relevant theory and experience support for enterprises.As a “going out” company in a central province of China,Z Company has been selected as one of the world’s top 250 international engineering contractors for four consecutive years.Its business covers transportation infrastructure,housing construction,energy minerals,agricultural development and many other fields,and is compared in the field of international engineering general contracting.Representative.To this end,this paper mainly adopts the case study method.Through the specific process of understanding the transfer pricing tax planning of Z company A country B project,it comprehensively analyzes how Z company can pass the transfer pricing when it faces the tax problem in the environment different from the domestic political economy.The tax planning method addresses these existing problems and achieves reasonable tax avoidance.Therefore,this article uses it as a typical case,which can provide more reference and enlightenment for foreign contracted engineering enterprises,and even provide relevant policy references for tax policy makers.The research in this paper mainly includes five parts.The first part is the introduction,including the research background,significance,method and overall research framework and literature review.The literature review mainly focuses on tax planning,transfer pricing tax planning and foreign engineering contracting enterprises.Research on transfer pricing tax planning conducted literature collection,classification,screening and review.It is found that the current theoretical research on tax planning and transfer pricing tax planning is relatively mature,but there is still room for further discussion,application and analysis on how to better use transfer pricing for tax planning and achieve reasonable tax avoidance.The second part is an overview of the transfer pricing tax planning theory for foreign contracted projects.It mainly includes the definition of relevant concepts,the introduction of the content,methods and characteristics of transfer pricing tax planning for foreign contracted projects.The third part is the case introduction.This part introduces the basic situation of Z company and the background,content and method of tax planning for transfer pricing of Z company A country B project.The fourth part is the case analysis.The case analysis is the key content of this paper.Firstly,the effect of the implementation of transfer pricing tax planning for Z company A country B project is evaluated,and the method adopted to achieve the above effects is analyzed,then Z The enlightenment brought about by the transfer planning and taxation process of the company A country B project was discussed.The fifth part is the revelation and suggestion.First of all,at the level of enlightenment,the main analysis of the transfer pricing practice of Z company has positive and valuable inspirations for tax planning in other foreign contracted projects in China.Secondly,it also puts forward corresponding suggestions and strategies for how foreign contracted engineering enterprises can better use transfer pricing for tax planning.Our study takes A country B project of Z company as A case study and studies the tax planning of transfer pricing of foreign contracted projects.The research shows that the scientific arrangement of business activities in enterprises and the legal tax planning with the help of transfer pricing strategy and different tax practices in different countries can effectively avoid the heavy tax burden.At the same time,according to the country where the project is located,the local pricing laws and regulations,the specific situation of the project,reasonable tax planning can obtain greater economic benefits.It is hoped that through the research of this paper,it can provide the corresponding theoretical support of tax planning for the operation decision of multinational enterprises,providepractical reference for Chinese enterprises to "go global",and enlightening for the transnational development mechanism and innovative management of Chinese enterprises. |
