Multinational Transfer Pricing Anti-avoidance Issues To Explore

With the further development of globalization of the world economy,multinational companies gradually increased in size and number.They play an important role as the organizers of the world's production and in the development of the world economy.However,since 2008 the spread of the financial crisis in the world caused damages to various degrees every sector.Many multinational companies which have been operating for decades collapsed in a night-time.How to reduce costs,to avoid taxes,to maximize profits through the winter, became the subject of multinational companies.As a government,how to curb the use of transfer pricing for multinational companies to avoid taxes has become an important issue which need to be solved immediately.In fact,with the change and concealment in ways to use transfer pricing of multinational companies,China's tax laws and the system gradually exposed its drawbacks.This article,based on the comparative studies and normative analysis,discussed the problem of China's transfer pricing and anti-avoidance tax avoidance.In the aspect of theory research,combined with the economic, management,accounting and other relevant principles,established the game model of the tax avoidance and anti-avoidance between multinational companies and tax authorities of host country.In the aspect of practice research, transfer pricing and tax avoidance in the relationship between research,based on the research of the relation of transfer pricing and tax avoidance,by comparing the anti-avoidance system of different countries,according to China's actual situation and in the light of international practice,make a suggestion of improve China's transfer pricing anti-avoidance system.In structure,this article can be divided into theoretical and empirical parts,in addition to the first introduction chapter and last conclusion chapter,there are four parts in the paper,ChapterⅢis a theoretical study,first of all,use the revenue cost theory to study how to formulate the optimal transfer pricing of multinational companies and the host country respectively,then use the economics models,analyses the game between the multinational companies and the tax authorities of host country.ChapterⅡ,Ⅳ,andⅤis the empirical research,based on comparative analysis of international transfer pricing anti-avoidance system,analyses China's current situation,pointing out the problem and put forward countermeasures and suggestions.This article has some features and innovations. Firstly,the economic,management,accounting knowledge were integrated,and made a careful analysis of transfer pricing.Through the expansion of the game model of transfer pricing, pointing out that in the scope of transfer pricing, multinationals and government departments like the two sides of game theory,they will always compete and struggle with each other.On the one hand, multinational companies manipulate transfer pricing maximally to minimize the tax burden.On the other hand,in order to protect its tax revonues, the tax authorities of host country continued to develop transfer pricing policies to control the situation.In order to study the factors that government needs to concern of transfer pricing anti-avoidance,and through further international comparison of transfer pricing of the tax system as a basis for China to complete the transfer pricing and anti-avoidance.Secondly,China's accounting system was questioned,in view of legislative gaps of transfer pricing of intangible assets in our country and the requirements of new economic development,the author proposed increasing in the corresponding anti-avoidance system.Thirdly,it is stressed that transfer pricing anti-avoidance is a systematic and complex project which need cooperation of domestic departments,as well as international.Accordingly, in this article,tax and non-tax system were proposed respectively,such as the maintain of related transactions still need further improvement,the increase in the special conditions in the use of intangible assets for transfer pricing tax,the system of increasing punishment in the use of transfer pricing for tax avoidance,improve the capitalization system, improve our tax system and institutions,and perfect the APA etc.