The Research On Transfer Pricing Of Intangible Assets Of Transnational Corporations

As for the transfer pricing,it is the main mean of international tax avoidance,and one of the most concerned tax issues of the governments of all countries.And nowadays,the transfer pricing of tangible assets has been deeply studied at domestic and abroad,but relatively,the research on the transfer pricing of intangible assets is still few.The characteristics of intangible assets,such as exclusiveness,non-entity and uncertainty,make it difficult to measure their value and compare with the uncontrolled transactions.In addition,under the digital era,intangible assets have played an increasingly important role in business operations.Even in some high-tech enterprises such as Apple,Google and Microsoft,intangible assets have taken the place of traditional ones.Accordingly,more and more multinational enterprises use transfer pricing of intangible assets to avoid tax burden.In order to safeguard our country's tax interests in the international economic activities,we should learn from the advanced experience of international organizations as well as other countries,to improve our international anti-tax avoidance system.Through the study of the strategy of Microsoft tax avoidance,this paper would find out the loopholes in the transfer pricing system of intangible assets in the United States.On this basis,the paper would analyse of China's tax system of the transfer pricing of intangible assets,and finally put forward some suggestions accordingly.