A Study On Legal Regulation Of Transfer Pricing Of Multinational Corporations

With development of the economic integration,multinational companies have become the most important part of the world economy.In order to reduce cost and increase profit,multinational companies take advantage of the differences in taxation of different countries,and they utilize various means of competition,and because of the asymmetric information,they can get huge profit through transfer pricing and evade their tax obligations.Therefore,this paper will use some cases and study OECD Base Erosion and Profit Shifting(BEPS)project and the newest progress of transfer pricing.Speak in a specific way,firstly,in the 21~stt century,the digital economy achieves rapid development.The intangible assets are rising shares of global trade.However,the intangible assets are uncertainty and monopolistic,the regulations are different with tangible assets,so it is difficult for the tax authority of a country to regulate the transfer pricing of intangible assets and the regulation also pay much more attention to it.The paper analyzes the problem through the case of GSk,and then study OECD regulations and regulations in America and Japan.Secondly,according to the international practice,the tax authority also adopts advance pricing arrangement,which will regulate before paying tax.It can achieve a win-win relationship between taxpayers and tax authority.So this paper tell the difference between American APA and Indian APA,and then study the APA in America,Australia,EU.Thirdly,when APA is put into effect,the tax authority cannot tell the difference among these dates.At this time,the tax authority will use the international exchange of tax information to get help from other countries.So this paper also study the case of Apple and Starbucks,and then learn the regulations in OECD,EU,America and England.Finally,the paper developments of transfer pricing in China,and give any advice.