A Study On The Transfer Pricing Adjustment Under The Background Of BEPS

With the deepening development of economic globalization and financial crisis,the competition and cooperation among numerous countries for maintaining national tax rights and tax interests have become more and more fierce and complex.Multinational enterprises are increasingly using transfer pricing for conducting radical tax planning,thus shifting profits and eroding the tax bases of other countries,which not only infringes on the government’s tax-raising rights and the fair competition rights of other enterprises,but also violates the fair taxation rights of the broad masses of taxpayers,resulting in an imbalance in the international tax order.On October 5,2015,the OECD released the final outcome as a response to base erosion and profit shifting,namely,“the BEPS Action Plan”.“The BEPS Action Plan” seeks to perfect and develop the existing international rules of tax treaty and transfer pricing,and create a fair tax environment and order globally.Many countries have actively responded to this and they profess to establish and improve the transfer pricing tax system so as to curb and fight against the behaviors of international tax avoidance.This paper discusses the new development of transfer pricing in the BEPS environment by using “the BEPS Action Plan” as the background,draws lessons from the action guidelines in “the BEPS Action Plan” that are related to transfer pricing on the basis of summarizing the previous practice of the transfer pricing theory in our country,and puts forward suggestions and countermeasures to perfect the transfer pricing tax system in China through the typical case analysis.The first chapter is the introduction,introducing the research background and research methods: a combination of theory and case analysis;the second chapter analyzes transfer pricing and the theory of transfer pricing anti-tax avoidance,elaborates the current situation of transfer pricing research at home and abroad and makes relevant evaluation;the third chapter introduces the new development of transfer pricing anti-tax avoidance in the background of BEPS,combs China’s transfer pricing anti-tax avoidance policies before and after the introduction of “the BEPS Action Plan” and analyzes the situation of the current transfer pricing anti-tax avoidance in our country;the fourth chapter finds out the problems and challenges faced by China’s transfer pricing tax system by analyzing the typical cases of transfer pricing and the BEPS;and the fifth chapter analyzes the deficiencies of China’s transfer pricing tax system according to the above chapters and proposes targeted suggestions and countermeasures to perfect the transfer pricing tax system reform in our country.