Research On Transfer Pricing Tax Risk Of Multination Company

With the massive emergence of transnational enterprises in China,it has played a positive role in China's economic development and promoted the transformation and upgrading of China's manufacturing industry.But it is worth our attention is that multinational companies to the rational allocation of resources,minimize risk,achieve global tax minimization,maximum economic benefits,the purpose of the use of regional tax rate difference for tax avoidance phenomenon intensified,and the transfer pricing has become an important tool of multinational enterprises tax avoidance.Internal transfer pricing occurs mostly in multinational enterprises,through the correlation between sales products,to provide business services,technology transfer,and money lending and other activities to the internal profit redistribution.Enterprises through the regulation of transfer pricing between affiliated parties undertake profit is the enterprise's legitimate rights,but once the transfer pricing policy does not conform to the transfer pricing compliance requirements,will cause itself to the attention of a tax authority or investigation,so as to bring huge economic,legal risks.Based on the case study of SG(wuhan)company,SG company headquarters is located in France,SG(wuhan)company is a wholly owned subsidiary company of the SG,between the interaction between mother and child company sales products,purchasing materials,authorized the use of related technologies,accept the business support and associated financing activities,its internal transfer pricing is worth as a typical case to study.This paper aims to solve the following key problems: 1.What is the situation of SG(wuhan)company's affiliated transaction? What is the transfer pricing model? Is this transfer pricing consistent with rationality and fairness? 2.How does the domestic transfer pricing law stipulate and how does it affect SG's tax risks? 3.How to avoid the tax risks of transfer pricing? Through the study of these three problems,a perfect tax risk control system is established and the awareness of tax risk prevention is raised.