The Research On Legal Supervison Of Transfer Pricing Of Intra-group Services Of Transnational Corporations

In recent years,many countries have paid more attention on tax evading and they have also realized that illegal transfer pricing has led to the loss of revenue.As the next wave of transfer pricing,the supervision of transfer pricing has become the focus of tax administrations.So tax administrations pay their attention to how to supervise the transfer pricing of intra-group services.This article point out the shortages of current laws of tax and give advices on consummating the framework of supervision system.This article especially focus on the transfer pricing of intra-groups in China,and propose to counsummate the supervision system.This paper is consisting of six chapters as followed:The first chapter mainly introduces basic concepts and the reasons of tax evading.Especially in the third part,the article introduces how transfer pricing of intra-group services becomes.This part also include the negative impact on countries' taxation and the importance of supervision.The second chapter analyzes the standards for determining the transfer pricing of transnational corporations in various countries,and points out the problems of applying the standards to identify the existence of labor transfer pricing in transnational corporations.The third chapter analyzes the transfer pricing supervision measures and the problems existing in the practical application.This part also points out the adverse impact of the application of regulatory measures.It tells the urgency and necessity of improving regulatory measures.The fourth chapter is to find solutions to the issue of supervision of transfer pricing of intra-group services.This part analyzes the regulations and practical experiences of the United States,Japan,and OECD.In addition,this chapter also tells the advantages and disadvantages of the improving measures and discusses whether this measures can be used by other countries for reference.The fifth chapter analyzes the current regulations of China's supervision of transfer pricing of intra-groups,and points out the problems existing in China's supervision,including the object of supervision,and the implementation of regulatory measures.This chapter also proposes how to improve the legal supervision of transfer pricing of intra-groups in China.