Research On Transfer Pricing Under The Circumstance Of E-commerce

E-commerce has been booming the entire world in resent years. As a kind of rising business operational mode, e-commerce represents the future of business, which not only has changed the trade style of consumers and enterprises, but also imposed deep influences on negotiation and operation of multinational companies. Comparing this, the development of law about e-commerce, including transfer pricing law, does not match that of e-commerce.How to protect the trade mode of e-commerce, create well investment environment of host country and protect economic benefit of host country, is the facing problem of tax authority all of the world under present economy environment. At present, international community become to focus on these problems, especially some developed countries and related organizations, which have began to do some research on the problems of e-commerce, enacted some law on e-commerce and made them perfect. Based on above, this article gives some suggestion about how to face these challenges brought by e-commerce in China.Apart from introduction and conclusion, this article is divided into four chapters:Chapter one: this chapter introduces connecting concept, principles and transfer pricing method about tax law system of transfer pricing. In the following, it analyses e-commerce's concept, characteristic and developmentChapter two: this part analyses challenges to transfer pricing tax law system brought by e-commerce, and how to reply these challenges in OECD, the US, the European Union and its parties.Chapter three: based on the introduction of previous chapters, this chapter examines fact patterns of some e-commerce business models, and analyses how the arm's length principle in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations could be applied to aforementioned business models.Chapter four: perfection of transfer pricing tax law system of our country under the circumstance of e-commerce. This chapter analyses status quo and limitations of transfer pricing tax law system of our country under the circumstance of e-commerce, based on which, it gives some suggestion on modifying present transfer pricing law of our country, refinement of taxation measures about e-commerce and standard management.