Research On Transfer Pricing Anti - Tax Avoidance Management In China Under Background Of BEPS

With the rapid integration of economic globalization,multinational business model,strategic planning in the ongoing changes.In the process of tax avoidance and tax avoidance with tax authorities in various countries,tax avoidance is endless.In recent years,multinational companies use capital weakening,cost sharing,controlled foreign enterprises and other ways to conduct tax avoidance more and more,but the transfer pricing is still the main means of tax avoidance,the above tax model is also the core of the Pricing issues.Therefore,the anti-tax avoidance investigation adjustment for the transfer pricing tax avoidance is the focus of the national tax authorities.China has started relatively late in the field of transfer pricing in western countries,but in recent years,with the increasing position of our country in the world politics and economy,the participation in the transfer pricing tax is getting higher and higher.The draft of the transfer pricing rules also incorporates many Chinese characteristics.Compared with the increase of the right of discourse in the international transfer pricing field,there are still some places in China to improve and improve the anti-tax avoidance management.The management of cross-border related party transactions of multinational companies needs to be improved urgently,which also affects our country's transfer pricing anti-tax avoidance work Comprehensive development.Therefore,it is of great significance to study how to improve the management of transfer pricing and anti-tax avoidance in China.This paper analyzes the problems existing in the management of transfer pricing and anti-tax avoidance in China,and puts forward some suggestions to improve the management of transfer pricing and anti-tax avoidance in China.The first chapter is an overview of the significance and background of the study,at home and abroad on the transfer pricing tax avoidance and anti-avoidance management of the relevant research results were summarized.The second chapter mainly introduces the concept of tax avoidance of tax avoidance and anti-tax avoidance of tax authorities.By analyzing the two rules of international transfer pricing system and the adjustment method of transfer pricing,it is necessary to judge whether the tax authorities' Principle to elaborate.The third chaptermainly introduces the development of anti-tax avoidance in China's transfer pricing,which includes the problems of anti-tax avoidance management and the problems brought by rapid development.Through the analysis of the problem,the author tries to find a solution.The fourth chapter introduces the investigation and analysis of anti-tax avoidance cases and the basis and method of adjustment.At the same time the investigation process encountered difficulties are listed one by one.The fifth chapter studies and studies the advanced experience of anti-tax avoidance management in developed countries,and strengthens and perfects the problems existing in the transfer pricing and anti-tax avoidance management.