Research On Anti-Tax Avoidance Of Transfer Pricing Within Transnational Corporations

With the development of international economic integration,multinational companies gradually increased in size and number.They play an important role of the organizers of world production, has played an important role in the development of world economy.In recent years, multinational companies use transfer pricing to avoid tax, the phenomenon is widespread in the world and presents a growing trend.For multinational companies, tax avoidance can reduce the tax burden to continue the pursuit of profit maximization; For tax authorities, the anti-tax avoidance can increase government tax revenue, to achieve fairness among taxpayers.Avoidance and anti-tax avoidance taxpayers and tax authorities will never be able to avoid the subject, this is not the smoke of war among nations. The same time, the means of tax avoidance of multinational companies are constantly renovated, has become more complex and hidden, for which countries have increased their anti-tax avoidance efforts to develop many new anti-tax avoidance laws and measures.Since the transfer pricing regulations promulgated in1998the first systematic specification, the transfer pricing practice in China for over10years of history. Along with China’s transfer pricing tax system from scratch, and developed into today’s special tax adjustments tax anti-avoidance, China’s anti-avoidance toward a more standard stage, the tax authorities continue to strengthen anti-avoidance efforts,significantly improved the quality and efficiency of the anti-avoidance work.According to the theory of international tax avoidance and anti-tax avoidance, with a focus on anti-tax avoidance of transfer pricing within international corporations and in-depth study of the anti-tax avoidance measures for multinational companies international tax avoidance and tax authorities.First of all, by the definition of the concept of multinational tax avoidance motive and means were analyzed to reveal the hidden and complex nature of the substance and the avoidance of tax avoidance of multinational corporations, and highlights the importance of multinational companies anti-avoidance. Secondly, the systematic analysis of the field of transfer pricing, tax avoidance and anti-tax avoidance, the status quo of China transfer pricing and the latest proposed the introduction and development of follow-up management of transfer pricing and advance pricing system in China. To establish a bilateral APAs system, the game model to analyze the effectiveness and feasibility of the process in their practice,for improving our country for advance pricing anti-avoidance measures.Finally, according to the analysis and summary of the discourse model, put forward proposals for multinational transfer pricing anti-avoidance policy.The result of this paper, will be provide that theoretical and practical significance. Provide theoretical support to broaden the thinking and vision of China’s anti-avoidance, and provide an analytical basis for our development of transfer pricing anti-avoidance measures to further promote the launching of China’s anti-avoidance.