Multi-National Corporation Transfer Pricing Influence On Tax

Multi-National Corporation in order to achieve the strategic target, achieve company profit maximization and cost minimization, by manipulating the transfer pricing methods for the Multi-National Corporation between the trade. Multi-National Corporation in international trade at the same time, the game and the host country tax benefits, this has caused me great interest.Because of the special nature of the rare earth industry I currently work at Multi-National Corporation department, this paper mainly studies the effect of transfer pricing case occurs in rare earth division for Multi-National Corporation tax, combined with the theory of transfer pricing analysis, in view of the influence of Multi-National Corporation have tax and future potential risks proposed and discussed.The main content is Multi-National Corporation transfer pricing related basic theories. The basic theory including the Multi-National Corporation uses motivation for tax planning of transfer pricing, the pricing method of transfer pricing is suitable for even bargain under the principle of transfer pricing, tax adjustment methods and the experience of management of transfer pricing. The Multi-National Corporation of rare earths division as the research object, aiming at the transfer pricing behavior of rare earths division has occurred which lead to the tax adjustment results and potential tax risk. From the case, we can found that tangible assets and intangible assets transactions, inevitably facing the potential risk of double taxation. For the rare earth company transfer pricing tax risk generated, using the advance pricing agreement of international (APA) scheme, the Multi-National Corporation get APA with local tax authorities, which can reduce the transfer pricing tax double taxation and the potential tax risk.