The Impact Of Intangible Assets Transfer Pricing On Tax Loss In Multinational Enterprises

Multinational enterprises will be high-speed development of science and technology to economic globalization as the carrier,the capital distribution in many countries.In order to reduce the overall tax burden of multinational enterprises,intangible assets transfer pricing has become an important way for multinational enterprises to choose.With the increasing investment of foreign capital in our country,tax avoidance in this way is more and more common,which not only intensifies the current situation of tax loss in our country,but also is a challenge to our tax jurisdiction.At present,there are many loopholes in the tax laws and regulations related to transfer pricing in our country,and there are some areas that need to be improved in the anti-tax avoidance practice.Therefore,based on the principle of fair trade,this paper emphasizes the contribution of Chinese enterprises to the value creation of intangible assets,and advocates the reasonable fight for the international tax rights and interests of Chinese tax authorities.In addition to the introduction,this paper is divided into five parts.The first part is literature review.The second part starts from the definition and classification of intangible assets,studies the main ways of transnational enterprises to choose intangible assets for related party transactions,and continuously erodes the legal tax base of our country by transferring profits to foreign countries.The third part is the case analysis,in the WD enterprise case analysis,we can find that it is due to the lack of attention to the management of intangible assets and too much emphasis on the proportion of intangible assets in value creation,resulting in our country should enjoy a large number of tax loss phenomenon.The fourth part mainly involves the analysis of the transfer pricing adjustment principle and introduces the use of profit segmentation method and reservation pricing method in China's intangible assets transfer adjustment operation,and the main provisions of the current laws and regulations.This paper also points out that the factors of regional special advantage should be added in the actual operation of China's transfer pricing adjustment,which is due to the consideration of the special economic environment and national consumption pattern.At present,China is actively engaged in anti-tax avoidance activities related to intangible assets,the state administration of taxation issued announcement No.42 requires eligible affiliated enterprises to provide timely related declaration and management of the same period of data is also constantly promote the process of anti-international tax avoidance,as far as possible to multinational enterprises tax avoidance motivation in a controllable range.The fifth part puts forward some suggestions on the anti-tax avoidance behavior of intangible assets transfer pricing in our country,emphasizes the importance of contribution factors of Chinese market in profit distribution among group enterprises,and maintains the jurisdiction of tax authorities in our country.At the same time,in order to improve the efficiency of tax authorities,we should constantly improve the database related to intangible assets in China,and improve the relevant system of intangible assets transfer pricing adjustment.