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Legal Research On Transfer Pricing Of Intangible Assets Under BEPS Project

Posted on:2018-07-24Degree:MasterType:Thesis
Country:ChinaCandidate:L Y HeFull Text:PDF
Abstract/Summary:PDF Full Text Request
As a booster of social and economic devel opment of intangible assets because of its own characteristics more and more dependent on multinational compani es.In the process of tax planni ng is al so more and more attention by multinational compani es.Multinational compani es use the traditional intangi bleasset transfer pricinglegal definition is unknown,the transfer pricing adj ustment method of the lack of legal collection and management procedures to the country caused the tax base erosion and profit transfer problems.The construction of new intangible asset transfer pricing rules to solve the probl em of tax base erosion and profit transfer is becoming a probl emthat OECD countries and other devel oping countries are trying to solve.Andlaunched t he BEPS project,forming a series of results.China's reform and openi ng up the pace of accel erati ng the market econony systemis increasingly perfect,the economic vitality has become increasingly prominent.Alarge number of multinational companies have their eyes into China,alarge number of foreign investors stationed in China' s market.Intangible asset transfer pricing has also beecone increasingly proominent.On the one hand,thi s has brought fresh vitality to our country's economic development,but it also brought the opport unity of multinational corporationstoavoid the tax administrationon and danage the tax benefits of our country through the taxplanning and transfer of the fair value of intangibleassets.Chi na has gradually become the hardesthit of transfer pricing,the intangible asset transfer pricing of the relevant legal issues in-depth theoreti cal di scussionis also very urgent.Therefore,it is urgent to perfect thelegal norns of transfer pricing to carry outlegal regul ation on the pricing of intangi bleassets transfer.BEPS project vigorous in the country after the start of our country al so began to build a complete transfer pricing system including cost-sharing agreemsnt and the arrangement of the pricing mechanism,and continue through practice to improve.Thi s paper attempts to transfer thelegal problens from the transfer of traditional intangible assets:the Iegal definition is unclear,the adjustment method is insufficient,the plight of the legal collection and namagenment procedures is raised and suppl emented by rel evant cases.And then through the BEPS project on the three issues related to the relevant provi si ons for the improvementt of nyrelated systemto come to inspirati on.Fi nally,the combination of China's current national conditions and the introduction of the relevant legal system and China's response to the BE PS project and the absorption of the project results and the comon cooperation with countries.And the analysis of the present situation of the existing legislation in China,absorbing the latest achi evements of the BEPS project to comment on the improvemnt of the rel evant tax system.
Keywords/Search Tags:BEPS, International Tax Laws, Transfer Pricing, Intangible Asset
PDF Full Text Request
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