A Study On Transfer Pricing Of Multinational Enterprises

This paper is divided into four parts. In the introductory chapter, the original intention of researching the multinational enterprises transferring price, and contents, way of thinking, method of research is elaborated on. And it points out some textual and creative. Firstly, it is to use the inductive method and the comparison method, summarizing the theories at each stage of multinational company transferring price from lengthways of time dimension, comparing the transfer pricing legislation of the United States and Japan. Secondly, in studying the contents, it is to lay particular emphasis on the important function of the legislation control, looking into the audit which influences on the strategy of multinational enterprise transferring the list price especially. In the second chapter, the theories of the transfer pricing analysis, it summarizes the main theories of four aspects--the creation, the development, confirming and decision etc, and presents the function clearly in the process of transfer pricing, as well as the influence on the multinational enterprise and the host country. In chapter 3, it induces the transfer pricing adjusting rules of OECD, and compares the adjust legislation control of the United States with Japan, putting forward that the audit of transfer pricing is one of the important factors which affect the decision of multinational enterprise transferring the list price. The model of the game is set up in chapter 4, which is to be analyzed the influence of the transfer pricing audit on the decision of the multinational enterprise. The conclusion is that the audit means is more mature, the audit is more successful, the punishing measures are more scathing, the risk of multinational enterprise abusing transfer list price is higher. Thinking of perfecting the adjustment transfer pricing legislation of our country is shown in the last chapter. The suggestions is to combine the legislation of adjusting transfer pricing, to strengthen the kit construction, to innovate the control principle and to extend the international cooperation respectively.