Research On Entitlement Of Tax Revenue,on The Basis Of Profit Split Method

There are five main pricing methods among the international transfer pricing rules: the comparable uncontrolled price method,the resale price method,the cost-plus method,the transaction net profit method and the profit split method.The front three methods have strict requirements on comparability during the application process.In the actual application of our country,the transaction net profit method is used most frequently.The two preconditions for the application of the transaction net profit method are: one party of the affiliated transactions undertake the limited functions and risks,and do not possess of high-value intangible assets;there are comparable related transactions and the comparable differences can be adjusted.However,intangible assets account for more than 80% of the market value of enterprises at present.The high degree of integration and incomparability make the transaction net margin method less practical in the transfer pricing.The profit split method is applicable to the situation of highly integrated affiliated transactions,where it is difficult to evaluate the transaction results of one party alone and all parties to the transaction have important intangible assets.This paper studies the practical application of profit segmentation to meet the requirements of economic globalization and digital economy.As the second largest economic entity in the world,China’s international status is improving day by day,and we should take an active part in the process of remolding international tax rules.The reasonable attribution of tax interests is an important prerequisite for the state to safeguard its legitimate tax interests.During the economic trades with other countries,especially developed countries,exploring the source and process of enterprise value creation which is based on the perspective of value contribution so that the value contribution of each related party matches the profit distribution is one of the important links in the current international tax research.At the same time,the market economy develop at full speed,the international status of our country is increasing day by day,considering the factors such as market premium and location savings,it is imminent to propose location specific advantages of our country that contribute to the enterprise value creation.Analyzing the approaches to dealing with Base Erosion and Profit Shifting(BEPS),can help increase the efficiency and level of job of anti-tax avoidance and defend the rights of legitimate tax jurisdiction.The first part of this paper is introductory theory.It describes the research background and significance.Relevant literature is summarized and summarized,as well as the main research methods and the structure.The second part is the concept definition and theoretical basis,focusing on the internal relationship between profit segmentation and tax benefit attribution,as well as the relationship and practical significance between transnational investment theory,factor endowment theory and global value chain theory.The third part is the status quo analysis,which mainly analyzes the relationship between the international tax environment and the profit segmentation method,the development and application status of the profit segmentation method and its influence on the tax benefit attribution,the international experience and the practical difficulties in the application of the profit segmentation method.The fourth part is the case study,which explores the rationality and scientificity of the application of profit segmentation through the typical application of profit segmentation in the transfer pricing of multinational enterprises by tax authorities,so as to make the tax benefits get reasonable attribution,find problems,analyze problems and draw conclusions.In the fifth part,the author puts forward policy suggestions,expatiates on the contribution and proposes the research prospect.In this paper,it draws the connclusion that in the international trade more frequently happened and international tax environment more for complex under the premise of profit split method in the field of transfer pricing undoubtedly play an increasingly important role and more frequent,based on the value of their contribution to multinational enterprises make a reasonable profit distribution so as to make the tax benefit of belonging is more fair and reasonable.The innovation of this paper mainly lies in the systematic elaboration of the practical significance of the application of profit segmentation from the aspects of theory and practice.At the same time,based on the traditional profit segmentation factors,this paper systematically and scientifically puts forward that attention should be paid to the location specific advantages of China and other developing countries and the extra profits brought to multinational enterprises.