A Case Study On Tax Planning Of Affiliated Transaction Pricing Based On Transfer Pricing In Huizhou Company Of Group A

With the continuous development of the world economy,more and more enterprises have achieved cross-border and cross-regional operations in order to enhance international visibility and seize international market share.Since tax laws and regulations in different countries and regions are different,and tax types and tax rates are also quite different,for multinational enterprises,the transfer pricing layout is an important means to adjust the profit level of each subsidiary and the overall tax burden rate.In recent years,the ties between tax authorities in various countries have become increasingly close,which has strengthened the supervision of the transfer pricing of multinational companies 'related party transactions.In this tax environment,how to seek the best pricing arrangement,reduce the overall tax burden,and increase the net profit of connected transactions conducted by multinational companies within the premise of compliance with tax laws and regulations has become an important tax issue for multinational companies.Based on the existing transfer pricing tax planning research literature and the research object of this article,this paper introduces the shareholding structure of the group to which the company belongs and the relationship Party's transaction situation,functional risk positioning,value chain positioning and transfer pricing tax planning plan.Secondly,the key points of this planning program were analyzed specifically,including the analysis of transfer pricing method selection,comparability analysis,and optimal related party transaction transfer price analysis.At the same time,relevant follow-up management analysis was conducted for this tax planning plan.Finally,the paper draws the following conclusions:(1)A Group Huizhou Company is a manufacturer and an optimal transfer price determiner and implementer in the transfer pricing tax planning scheme;(2)The appointment pricing arrangement is The optimal result of transfer pricing tax planning can effectively reduce the risk of tax planning.The profit gained by APA companies should match the functions they perform and the risks they bear,and they must pay attention to the company's functional risks and value chain positioning;(3)Real-time adjustment of tax planning plans should always maintain a high degree of internal and external environmental changes attention.When formulating the transfer pricing tax planning plan,you should choose the appropriate transfer pricing method and pay attention to the analysis of comparability,so as to more effectively prove the reasonableness of the price of the related party transaction;Companies have to pay attention to the maintenance of relations with tax authorities and establish good tax-enterprise relations.In this paper,through a detailed study of the transfer pricing tax planning plan of Group A Huizhou Company,for the purpose of reducing transfer pricing tax risk,lowering overall tax burden,and increasing after-tax profits for manufacturing multinational companies,they formulate transfer pricing tax planning for their internal related transactions The scheme has certain reference significance.