Research On Optimizing China's Intangible Asset Transfer Pricing Tax System

The establishment of any tax system is a process of continuous improvement.In this process,there will always be some omissions for individuals or enterprises to have a chance to use these imperfections and loopholes to achieve their own tax evasion and tax avoidance purposes.This is the process of establishing an intangible asset transfer pricing tax system.In the context of the globalization of economic globalization,multinational corporations have become increasingly attractive business methods.The purpose of the existence of the enterprise is to maximize its profits and minimize costs.Therefore,multinational corporations will focus on the transfer pricing of intangible assets and achieve the goal of reducing the total tax burden of enterprises in the global business scope through improper manipulation.At the same time,however,such tax evasion and tax evasion will inevitably have an adverse impact on the taxation rights of the countries concerned.Under the background of using intangible asset transfer pricing as a means to reduce the tax burden,the traditional anti-tax avoidance means is weak,and the BEPS action plan came into being.The OECD has refined the intangible asset transfer pricing tax system by proposing a BEPS action plan,with a view to meeting this problem.This paper begins with the basic theory of intangible asset transfer pricing tax,sorts out and analyzes the latest research results of intangible asset transfer pricing,and elaborates on the new development of the definition of intangible assets and the confirmation principle of intangible asset transfer pricing transactions under the BEPS action plan.And through the comparison and analysis of the intangible asset transfer pricing cases before and after the implementation of BEPS,that is,the difficulties and counter-tax avoidance of the tax authorities before the implementation of the BEPS action plan,and the advantages brought by the anti-tax avoidance work after the implementation,and then learn from the United Kingdom,Brazil and Japan.Waiting for the advanced experience of localization of relevant regulations in BEPS,and finally propose targeted countermeasures for taxation optimization.