Foreign-invested Enterprises In Transfer Pricing Research

Transfer pricing is the inevitable product of internal transactions of the foreign investment enterprises ("FIEs"), is the necessary management means of FIEs and is the powerful tool to achieve strategic objectives of FIEs. Therefore, the FIEs, tax authorities and accounting firms have pay more attention on it.With the continuing reforming and opening up, China has attracted a growing number of FIEs investment, then the taxation problem of transfer pricing also existed in our country, so the tax authorities have paid more attention on this issue and have taken relevant measures to investigate this issue.In my paper, the study method is from theory to practice, and give some suggestion to perfect the transfer pricing taxation system of our country in the end. The paper mainly includes '4 aspects. In the first place, I take the theoretical analysis of the taxation problem of transfer pricing. From the point of view of taxation, the transfer pricing of FIEs may damage the tax bases of a country, cause the international tax controversy and bring the international double taxation problems. Secondly, I analyze the phenomenon and the characteristics of this issue in our country. In my opinion, the "double tax avoidance" phenomenon is existed in our country. Thirdly, I do the analysis and research of US and OECD's transfer pricing taxation system. Finally, according to the flaw of our transfer pricing taxation system, I provide some suggestion to perfect it.In my mind, facing the taxation problem caused by the transfer pricing, our country should take relevant measures to solve this issue. In the one hand, our country should continue perfect the transfer pricing taxation system to protect the tax bases. In the other hand, our country should encourage the practical use of the bilateral or multilateral Advanced Pricing Agreement and the simultaneous tax examinations to avoid the international tax controversy and the international double taxation problems.