AQ Company's Research On Transfer Pricing Policy Based On Value Chain

In June 2017,in the Tax Basis Erosion and Profit Transfer(BEPS)8-10 action plans,transfer pricing regulations put forward more strict provisions,requiring the countries should formulate the appropriate domestic transfer pricing rules in accordance with the global transfer pricing guidelines.The multinational enterprises usually set up a value chain of a group,and this research is to make use of the value chain method to analyze the pricing policy of related party transactions,which is considered as a good theory and with meaning of reality.This research is divided into five chapters.Chapter 1 puts forward the research questions,the purpose and significance of this study,the domestic and overseas research status,and puts forward the research ideas and frame of how to use value chain analysis making the company's related party transaction pricing policy research.The second chapter introduces the principles and motivations of related party pricing policy and value chains brief introduction.The third chapter takes AQ company as the research object,and the current situation of AQ company's pricing policy of related party transactions.The fourth chapter explores AQ's value chain analysis the functional differences between AQ's two products,and analyzes the related value contribution and core profit driving factors.The fifth chapter mainly studies the implementation of related party transaction pricing.The cost plus method and the value contribution allocation method are selected as the research object of related party transaction pricing through the feasibility study of the related party transaction pricing method.At last,this research represents some suggestions on the implementation of the policy so as to reduce the risk of transfer pricing tax supervision and improve the efficiency of tax compliance.The last part is the conclusion and significance of this research.In this research,we adopt the research ideas of discovering problems,verifying research,analyzing problems and solving problems.Through the study of the theory and practical cases of the pricing arrangement of related party transactions under the value chain analysis,we adopt qualitative and quantitative methods to study the pricing of related party transactions of different products under the value chain of AQ Group.Finally,a pricing method with high practical significance is established for AQ's products pricing.The innovation of this research is that the value contribution allocation method is a relatively new method of transfer pricing analysis which can be adopted in China's transfer pricing laws and regulations.This method is adopted in this practice of enterprise research,which has the important practical significance on the related transaction pricing based on value chain analysis.