Research On Connected Transaction Transfer Pricing Tax Planning Of A Company

Transfer pricing is the pricing of all business transactions of related parties.Transfer pricing tax planning is to maximize the profit by reducing the overall tax amount through arrangements for the pricing of related party transactions.With the increasing number of internal transactions of multinational group companies,It becomes more and more important.However,with the development of the BEPS project,Many countries apply automatic exchange of financial account tax information,more transparent tax information,Which lead less space in tax planning.At the same time,the tax authorities frequently investigated transfer pricing and severely cracked down on tax evasion.Therefore,corporate tax planning for transfer pricing will face more challenges and doubts.Domestic and foreign experts have also carried out many researches on this and analyzed the tax planning theory and methods of transfer pricing from different angles and conducted empirical analysis.However,there is less consideration of a group company's transfer pricing tax planning involving different industries such as logistics.In view of this,this article takes the logistics division headquarter of the group company,company A,as an example to study the transfer pricing tax planning of a large number of connected transactions between subsidiaries in the logistics industry,providing practical reference for enterprises and tax authorities,helping enterprises to develop a reasonable transfer pricing policy and plan tax reasonably,and benefiting for tax authorities in transfer pricing and surveys to identify taxpayer tax risks.This article is divided into six parts.The first part mainly introduces the current situation of research at home and abroad.The second part elaborates the theory of transfer pricing tax planning in three points: tax planning theory,transfer pricing theory,and transfer pricing tax planning theory.In the third part,we collated the overview of A company's related party transactions,first introduced the general situation of company A and stated the current situation of company A in logistics industry.then do some basic analysis for key indicators of the logistic industry in 2017 with the situation of company A.At last,sorted out the A company's existing related transactions,displayed the existing related transaction data and analyzed the proportion of A company's related party transactions.The fourth part mainly analyzes the four major related transactions of Company A: the headquarters service fee,R&D and technical services,call services,and the status quo of the mutual provision of logistics services between subsidiaries,then analyze the functionand risk in the transaction with combining company A and its associated subsidiaries.Through the analysis of functional risk,combing out more suitable transfer pricing method for A company's existing connected transaction.It also pointed out the major four related transactions of Company A.In the fifth part,in response to the specific issuesof the four major related transactions of company A proposed in the fourth part,combined with preferential tax policies,a more optimized tax planning program was designed.The advantage shows clearly of new tax planning program through the data comparison between the old and new programs.At the same time,the safeguard measures were summarized from the status quo of company A.They were: setting up an independent transfer pricing department,establishing a transfer pricing system,and seeking the support from external professional consulting companies.Finally,the article concludes that the company needs to combine preferential taxation policies,conduct related-party transfer pricing tax planning,A company should establish a corresponding transfer pricing system,monitor the overall situation of transfer pricing in real time,and incorporate risk indicators for warning the corresponding Risk early.A company's related party transaction transfer pricing tax planning need to consider further reasonable reduction of tax burden and reduce the risk of tax planning.