The Research On Anti-tax Avoidance Management Mechanism Of Transfer Pricing Of Marketing Intangible Assets In China

China's management of transfer pricing started in the 1980 s.After nearly 30 years of development,the transfer pricing laws and regulations system has evolved from scratch and has been continuously improved.The level and effectiveness of anti-tax avoidance have also been continuously improved.But for the new intangible assets that are created by marketing activities such as marketing and promotion—marketing intangible assets transfer pricing anti-avoidance problem.Compared with Western developed countries,China's relevant laws and regulations are basically blank,lacking systematic and detailed regulations;in terms of practical operations,due to the complexity of intangible assets and the particularities of developing countries,they also encountered difficulties in the anti-tax avoidance process.Less problem.Mainly manifested in: the entity lacks the specific provisions for the transfer pricing system of marketing intangible assets,the definition of the scope of marketing intangible assets is not clear,etc.;there are non-standard tax collection and management procedures in the management mechanism,the audit mechanism is incomplete,the talent reserve is backward,and the burden of proof is allocated Unreasonable,the punishment is weak.In 2017,the State Administration of Taxation clarified the “Special Tax Investigation Adjustment and Mutual Negotiation Procedures Management Measures” issued by the State Administration of Taxation,clearly pointing out the impact of the transfer pricing of intangible assets by some multinational companies on China's taxation,and regulating the scope of application of tax adjustments.Judgment criteria,etc.This paper uses the theoretical methods in the public management discipline to comprehensively analyze the deep reasons for the tax avoidance of marketing intangible assets transfer pricing from the aspects of tax system design,law enforcement defects,and personnel quality.In addition,we should draw lessons from the comparative study of taxation systems and taxation management theories of Western companies.As a result,China should quickly promote the introduction of specific laws and regulations concerning the transfer pricing of marketing intangible assets,define marketing intangible assets,and establish a strict taxation system.Enhance tax collection and management,increase anti-tax avoidance and punishment,rely on anti-avoidance tax information system,strengthen anti-tax avoidance cooperation at home and abroad and other effective anti-tax avoidance measures,and comprehensively implement anti-tax avoidance management in order to maximize the reduction of tax avoidance.Targeted anti-tax avoidance management research not only has great significance for the scientific tax collection and management of the new era,but also is an important part of adapting to the needs of the new type of public government reform and establishing a scientific public finance management model.At the source,it seeks to solve the reasonable path of tax avoidance for transfer pricing of marketing intangible assets.