Distribution Of Burden Of Proof In The Tax Collection Of Intangible Asset Transfer Pricing

Under the background of global economy,the trading between transnational corporations are causing different types of International Taxing Problem,even causing The tax base erosion and transfer profit(BEPS).And the Transferring Pricing,because of it is relatively elusive in affiliated corporations,are becoming one of the challenges of International Taxing.The major principle of Transferring Pricing is The Arm's Length,according to which,the trading price between affiliated corporations needs to be comparable with those independent corporations.Of all those Transferring Pricing tools,the Intangible Property is the most complicated one.And the corporations are using the Cost Contribution/Sharing Agreements(CCA)to transfer profits,some even causing the tax base erosion.While the tax authorities will accordingly adopt manner of verification collection.According to the current law in China,the CCA is allowing to adopt to share costs between affiliated corporation on the basis of the value contribution.While once under verification collection,the tax authorities will inspect if the CCA has economic essence,and the corporations need to prove the CCA is reasonable through the same period about relevant trades(PRT)reports.The rules in burden of proof are now ambiguous,especially on Intangible Property,so this article are aiming at the propose of better applying CCA mechanism,and sound the taxing system through studying the burden of proof in the stage of verification collection on the Intangible Property.