| Due to the differences in tax preferential policies of different regions and industries,the internal market of domestic conglomerates has tax avoidance effect,and the tax risks of related transactions are becoming more and more serious.The related transactions of intangible assets being more hidden.Based on the high risk of intangible assets related transactions,how to effectively monitor through the risk management system and quickly investigate,identify,evaluate and cope with its potential tax risks is the focus and difficulty of tax risk management.However,no matter in the previous academic discussion or in the real tax practice,more attention is paid to the intangible assets transfer pricing of transnational enterprise groups,while relatively little attention is paid to the intangible assets tax avoidance between domestic affiliated enterprises.Ignoring this problem will restrict the improvement of the quality and efficiency of tax risk management and affect the overall tax burden level of the country.Therefore,this paper selects three representative cases of tax risks of domestic related transactions managed by tax authorities,and focuses on three important intangible assets,namely land use right,trademark and copyright works.Through intra-case analysis and cross-case analysis,the paper finds out the difficulties and weaknesses in various links of tax risk management:during risk identification,information is asymmetric,sharing channels are narrow,traditional indicators fail;during risk assessment,qualitative rules are unclear,valuation methods are not mature;during risk response,there is significant resistance to investigation and evidence collection,adjustment procedures and methods are not applicable.This article proposes targeted countermeasures and suggestions based on the analyzed problems and causes.At the level of identification mechanism,it has improved the related party identification method,established an information base and identification indicators;At the evaluation mechanism level,a risk level evaluation and ranking model is constructed to optimize the intangible asset valuation method;At the level of response mechanisms,the process of determining the final response level has been revised to promote the improvement of response measures.This article has verified through multiple case studies that there are common difficulties in tax risk management in domestic intangible asset related transactions.It proposes tax risk management strategies from the perspective of tax authorities,making a theoretical attempt to effectively identify,evaluate,and respond to tax risks in actual collection and management,which is conducive to further standardizing intangible asset related transactions,helping tax authorities improve their ability to counter tax avoidance in domestic related transactions,and recovering national tax losses,It also provides reference for audit work to improve the level of risk prevention at the tax level. |
