A Research Of Anti-avoidance About Royalties Of Transfer Pricing

In the process of the sustained development of economic globalization multinational companies will evade taxes through a variety of means in order to obtain the biggest profits.There are national differences of the tax law between different countries,and there are a lot of loopholes in the international tax system.Transfer pricing between affiliated enterprise has become a major means of tax avoidance.In the high speed of science and technology innovation,the value of royalties grow Faster and faster.People pay more attention to royalty transfer pricing.Tax avoidance through the transfer of intangible assets has two ways:transfer of ownership of the intangible assets,through the difference between actual value and the transaction price for tax avoidance;Another one,transfer the right to the use of the intangible assets.In our country,it is relatively rare of multinational companies transfer ownership of intangible assets.So this article focuses on the transfer of the right to the use of intangible assets,the royally of transfer pricing related tax issues.The existence of royalty transfer pricing,not only causes the country's fiscal revenue cuts,but also and it will impact the tax failmess.However,the existing tax system in our country can't effectively dock with the international tax law,especially in royalty loopholes in transfer pricing.Firstly,I have illustrated the meaning of my choice and put forward the main problems discussed in this article.Secondly,according to the economic characteristics of the royalty transfer pricing and the royalty in the form of transfer pricing in China,I have analyzed the influence of our country by transferring royalty,and I have confirmed the necessity of anti-avoidance to transfer pricing.Then I have introduced our country royalty transfer pricing tax policy evolution,and the adjusting method and the basic principle of transfer pricing,respectively analyzes their limitations of transfer pricing.And then I have compared the royalties on intermational transfer pricing different practice of anti-avoidance.Finally,I have proposed consummates advice of royalty transfer pricing tax for our country.