Tax Law Study On Multinational Corporation Regional Headquarters

In recent years,many governments attract the Multinational Corporation RHQs by putting preferential tax treatment, it has been an outstanding phenomenon. Another aspect, many Multinational Corporations make use of the form of RHQs to evade tax. How to interposing a set of comparatively rational taxation system which can attract the RHQs and also prevent the RHQs avoiding the tax by transfering pricing and defend our country's tax revenue benefit is an outstanding issue our contry must be faced.The topic of this article is about the above issue.The author puts the point of the following study: one is how to attract the RHQs in the tax system, and the other is how to effectively administrate the RHQs in the tax way and prevent it from the tax avoidance. The purpose is to find out the law countermeasure to perfect the tax law legislation and improve the quality and the efficiency of the international tax administration.The article is divided into five major chapters:Chapter I: The author summarizes the fundamental theory of Multinational Corporation RHQs and tax administration,including the law concept and law characteristics,and the relation of the RHQs'selling characteristics and tax administration.Chapter II: The author discusses the tax law international experiences of Multinational Corporation RHQs, one is the tax law regulation of American,United Kingdom and Japan, two is the tax regulations of the Singapore and Hong Kong.Chapter III: The author summarizes the tax important problems about the RHQs,including the RHQs'tax sensibility, RHQs'non- tangible property transfer pricing tax system,and the thoery of"non-trade foreign currency paid".Chapter IV :the author introduced the existence problems of China's tax law legislation and practices of Multinational Corporation RHQs, such as the preferential tax policy, the difficult point analyes of the transfer pricing tax administration of the RHQs which is including the challenge to our international tax legislation,the tax administration style,the tax administration means. In the final chapter, according to the international expericese and our country's practice,the author put forward some suitable legislation and practice proposals in Multinational Corporation RHQs .