Research On Transfer Pricing Application

Along with the global integration of management, Multi-National Corporation to enhance the competitiveness, realize its global strategy, to seek maximum benefits, many strategies and methods adopted. In its pursuit of maximizing the interests tend to the pursuit of profit maximization, while the use of transfer pricing to implement tax planning is one of the ways to realize the profit maximization, is the most commonly used strategies and methods.In this paper, from the company’s point of view, the application of transfer pricing in the tax planning method to carry on the research analysis, by comparing the domestic and foreign Multi-National Corporation application of transfer pricing behavior, the exploration can suitable for China’s Multi-National Corporation (taking ABC company as an example) in international business activities in the use of strategies and methods of tax planning of transfer pricing, expectation to provide a useful reference for our company, and also help the tax planning of the academic circle of our country transfer pricing.In face of the fierce competition of international market, sharp exchange rate fluctuations, national tax are different, this study will help China to explore the use of transfer pricing the Multi-National Corporation means in the application of tax planning, and gives a useful way to maximize operating profits, and maximize the whole interest.This paper expounds the purpose and significance of writing; relationship, motivation and transfer pricing and tax planning; transfer pricing application in tax planning formulated in terms of form and decision mode, principle and theory model; the basic method of transfer price by tax planning and evaluation; the domestic and foreign Multi-National Corporation to use transfer pricing tax planning comparison Multi-National Corporation; use transfer pricing to explore the strategy of tax planning, such as the influence of the government, to transfer pricing restrictions (OECD and APA), and introduced quantitative mathematical model, analyzed by the enterprises under the conditions of different tax rates of the transfer pricing strategy of tax planning.By ABC company’s transfer pricing tax planning case study and explore the use of transfer pricing tax planning strategies; and finally the implementation of transfer pricing tax planning policy recommendations, to multinational enterprises in our country use transfer pricing for tax planning to put forward the policy and specific suggestions and provide some reference and guidance.During the writing of this paper systematically combines the internalization theory, the decentralization theory, profit transfer theory, transaction cost economics, accounting and mathematical programming model theory knowledge, through combing the relevant documents, the combination of comparative analysis and comprehensive analysis research. Through the examples of ABC company, method to build a model to explore set the transfer price to implement tax planning, for the management of multinational companies in China and to provide a more in line with the company’s actual tax strategies and methods.The innovation of this paper is to use the case data of actual concrete, combined with risk consideration, data model and decision and relevant theoretical knowledge, comprehensive consideration of the enterprise income tax, tariff tax planning, and provides solutions for a number of management needs and objective; combining the cost behavior analysis, financial budget, transfer pricing, quantitative model can dynamically to carry out tax planning.This paper proves that the tax planning strategy plays an important role to achieve business objectives by using transfer pricing of Multi-National Corporation.