| Economic globalization has brought about the internationalization of taxation.In this process,more and more traders,in order to pursue greater profits,transfer profits to countries or regions with low tax burden through connected transaction,which seriously erodes the tax base of their home countries and affects the fairness of international taxation.In this context,the G20 leaders summit promoted and entrusted the OECD to implement the BEPS action plan,aiming to improve the problem of related enterprises using connected transactions to evade taxes.This paper focuses on the analysis of the legal regulation of tax avoidance through connected transactions,which is mainly divided into five parts.The first part introduces BEPS and BEPS action plan at the beginning,and then analyzes the definition of connected transactions and transfer pricing,so as to draw out the thinking object of this paper.The second part analyzes the regulations on tax avoidance of related party transactions in the BEPS action plan from the two perspectives of controlled foreign company rules and arm-length principle,which are more comprehensive in this aspect.The third part still summarizes the current situation of connected transaction tax avoidance in China's laws and regulations from these two perspectives,but analyzes some deficiencies under controlled foreign company rules and arm-length principle in a more detailed and in-depth way,especially the lack of clear definition of the two rules.In view of the above deficiencies in China's regulations,the fourth part discusses the necessity of drawing lessons from relevant suggestions in the BEPS action plan from the macro perspective of international tax cooperation and China's economic development.In the fifth part,from the perspective corresponding to the above,it analyzes the points that China can use for reference from the BEPS action plan to improve China's legal regulations on tax avoidance of connected transactions. |
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