| Transfer pricing is an important means of tax planning for affiliated enterprises.Affiliated enterprises can transfer profits between different parent and subsidiary companies through transfer pricing of affiliated transactions,change the distribution of profits,and thus affect the overall tax burden of enterprises.The introduction of preferential income tax policies makes the applicable income tax rates of affiliated enterprises different,which makes it possible for affiliated enterprises to make transfer pricing and tax planning by using the difference in income tax rates.With the introduction of various national preferential tax policies,it has become an essential strategic planning for affiliated enterprises to develop transfer pricing and tax planning by relying on their internal affiliated companies in order to maximize the overall profits of the enterprises.However,in this process,if the preferential income tax policy is used blindly or improperly,in violation of relevant laws and regulations,it will lead to punishment from the tax authorities.Instead of saving tax for the enterprise,the enterprise will be punished and increase expenditure.With the help of the linear programming model,this paper studies the transfer pricing and tax planning of raw materials purchased by company B from company Y by taking company B with high-tech enterprise qualification and its subsidiary company with software enterprise qualification(hereinafter referred to as company Y)as the case.Based on contract theory,game theory and other relevant fiscal and tax theories,this paper first analyzes the business status of the case company and its external fiscal and tax environment,and draws the conclusion that company B’s adoption of unreasonable transfer pricing for "tax avoidance" brings significant risks to the company.On this basis,according to operating characteristics of B company and combining with the provisions of the laws and regulations of the affiliated party transfer pricing method,using linear programming model of transfer pricing during the course of a single linear programming model to model,and combining with the operating data of company and a Y B to B company’s overall profit maximization as the goal of its transfer pricing to solve the optimal solution.According to the formulation of the optimal transfer price,the case company with significant tax risks can substantially reduce the tax risks,and save tax payment for the company on the basis of complying with the requirements of laws and regulations,so as to achieve the goal of maximizing profits.Finally,the paper discusses the linear programming model of multi-period transfer pricing,which can be used as a reference for enterprises to make long-term tax planning plans. |
