Research On Transfer Pricing Of Marketing Intangible Assets In Tax Legislation

With the globalization of the economy and the emergence of new business forms,the phenomenon of transnational corporations using transfer pricing for radical tax planning has intensified,and the tax benefits of various countries have been affected to varying degrees,especially the use of transfer pricing mechanisms by multinational corporations.Internal transactions make the legal form and commercial substance more and more contrary,especially the marketing intangible asset transfer pricing,because the form of such transfer pricing is not accurately located at the legal level and the economic level,which also makes marketing intangible assets Transfer pricing practices are highly controversial.However,the transactions related to marketing intangible assets have been continuously expanded with the trend of international economic integration,and the pricing of marketing intangible assets has become more frequent and extensive.In order to improve the legal system and norms of the pricing of marketing intangible assets,the US IRS and the OECD have made legislative attempts and achieved many positive results.China's research in this area is relatively late,and the research is in the initial stage,and no effective legal system has been formed.In particular,the issue of pricing pricing for marketing intangible assets has not been effectively solved,which makes Chinese multinational companies in international trade.The disadvantageous position is often the risk of double taxation,and China's taxation benefits will be subject to certain damage.This article mainly takes the GSK case as an example,expounds the contents of the US Internal RevenueService and the OECD on the pricing of marketing intangible assets,and deeply explores the problems and shortcomings of marketing intangible assets in transfer pricing.It provides a reference for the construction of China's transfer pricing legislation system.In the research process,this paper elaborates on the transfer pricing of marketing intangible assets based on transfer pricing,and discusses the relevant regulations of the US IRS and OECD on the pricing of marketing intangible assets from the background and methods.Research on the existing tax regulations in China,and compare the two,find out the shortcomings in the current legislation in China,and put forward relevant suggestions.The first part of this paper mainly introduces the particularity of marketing intangible assets through the analysis of GSK case.The second part specifically discusses the ownership and profit distribution of marketing intangible assets.The third part mainly analyzes the various pricing of marketing intangible assets.The adjustment methods and comprehensive analysis of these methods are carried out.The fourth part provides constructive suggestions for the construction of China's marketing transfer pricing legal system based on the above contents.