Research On The Regulation Of Transfer Pricing Of Marketing Intangible Assets

How to adjust the transfer pricing behavior of marketing intangible assets,whether in the theoretical research of the relevant international tax law and the handling of cases,there are problems that need to be resolved urgently.The problem of transfer pricing tax avoidance of marketing intangible assets is difficult to solve,mainly because of the particularity of the production and income of such intangible assets.There are two main types of tax avoidance of marketing intangible assets of multinational companies.One is that the production and value of assets are mainly derived from a large amount of marketing cost input without corresponding economic compensation;the other is that the production and value of assets are mainly derived from the location of subsidiaries.The country where the market is located with special geographical advantages does not impose corresponding tax on this.In the current environment where marketing intangible assets are widely recognized,if the transfer pricing of marketing intangible assets violates the principle of independent transactions,artificial profit transfer will occur and the tax base of the country where profits are lost will be eroded.In this regard,there is a need for regulation.At present,the international community has formed a regulatory system that takes the principle of independent transactions as the basic principle and the global formula method as an important alternative method.In addition,it also supplements the three principles of economic substance,commercial rationality,and realistic and feasible choice.However,there are still dilemmas such as the uncertainty of asset generation and value,the controversy of ownership and income distribution,and the inability of existing principles to adapt to actual needs.In order to resolve many of the above-mentioned problems,it is necessary to sort out the current situation of my country's marketing intangible asset transfer pricing regulation.In terms of theoretical research,scholars have conducted extensive research from different perspectives of taxation authorities and affiliated companies;in terms of the current system,my country has also experienced a development process from principled regulations to specific and operable regulations.However,these traditional theories and regulations do not take into account the special economic factors of China as a developing country,nor can they protect the value created in the operations of multinational companies,and there are also areas that need to be improved.The difficulty in defining marketing intangible assets,tax information barriers,and the limited role of traditional tax base division standards are all difficult problems faced by regulation.For this reason,it is necessary to outline and analyze the OECD and the US marketing intangible asset transfer pricing system,and find a regulatory method suitable for China's current situation.First,improve the definition of marketing intangible assets;second,clarify the scope of marketing intangible assets;third,strengthen the communication and cooperation between tax authorities and related companies;finally,strengthen multilateral consultations on international tax cooperation,and look at marketing from the perspective of global economy The division of the tax base of intangible assets has actively promoted the signing of multilateral taxation agreements.