Transfer Pricing Of Intangible Assets And Its Adjustment

The particularity of intangible assets makes the tax authority very difficult to affirm and adjust the transfer price of the intangible assets. This also makes the transfer pricing of intangible assets and its adjustment problem become one of the questions that cause discussion and dispute in large range in the world, the major focuses of which is the specific method of adjustment. Besides the traditional methods that fixed by OECD originally, new methods are put forward successively. Each has pros and cons and applicable condition. As investment in China of trans-corporation becomes more and more, the problem of transfer pricing of the foreign-investment enterprise is also stressed increasingly. However, since the system of transfer pricing of intangible assets in our country is not perfect, the intensity of adjusting for it is very weak. Therefore, the research on this aspect is in great need. Basing on the characteristics of intangible assets and its transfer, the text recommended research, practice and innovation about transfer pricing of intangible assets in OECD and the U.S.A, who represent the most forward position of this field; Introduced the new methods auspiciously through the instance. Finally, it analyzed the situation of transfer pricing of intangible assets and its adjustment in our country, and then put forward the ideas about how to improve the system.This text divides into four parts:First part, begin from the introduction of basic conception and principle oftransfer pricing, and then drew forth the important part among them--thetransfer pricing of intangible assets, then recommended the expounded definition, price structure and particularity of intangible assets, as well as 3 kinds of modes of transferring in detail.Second part, introduced the legislative course and its main content in adjustment of transfer pricing of intangible assets in OECD and the U.S.A. separately, and explained the three basic principle of adjustment. Then introduced...