A Case Of Prevention And Control About Hitachi Suzhou Transfer Pricing Tax Risk

Resources and humanresource advantage attractive foreign investme nt to china toset more manufacturing enterprise, the trans fer pric ing tax system in our country isincreasingly perfect and standard, the tax authority anti-avoidance operating processis becoming more and more effic ient, limited functio n of enterprise is facing moreserious risk of tra nsfer pric ing ta x because of more strictly trans fer pric ing taxsystem.Hitachi Suzhou belongs to the comp uter hardware ma nufacturing, Hitac hi disp layco.LTD a nd Hitachi China co.LTD are controllingshareho lders, limited function o fenterprise, products are sold back to Hitachi d ispla y co.LTD. In the industry property,equity structure, function and transaction model fits well with single function riskenterprise, as a representative of the ma nufacturing, Hitachi Suzhou situation and thetransfer pric ing ta x risk, as well as its strategies, are typica l and representative. It isvery useful to analyzes the trans fer pric ing risk preve ntion and control strategies ofHitachi Suzhou. The biggest risk of Hitachi in Suzhou is that its rate of profit is not inthe market standards, puts the cost plus rate too low。In preparation for the sa me datawill be invo lved in the process of the ana lys is o f the trans fer pricing methods,accord ing to the provis ions of the tax law and the ir own particularity to choose themost appropriate pric ing method, expla in the pric ing reason and the reason in detail.Let the tax authorities know the proble m of enterprises, such as the ris ing labor costs,rising cost of raw materials, etc.The key of enterprise risk preventio n and control of trans fer pric ing ta x measuresand operation can include fo ur points.F irst, understand ing the ta x law a nd the taxregulation e nviro nment o f enterprise. It should not touc h the law of red line, theinformatio n should conform to the require ments o f the local tax a uthorities. Second,set up the tax risk identificatio n and assessment mechanis m based on the same datatransfer pricing, us ing the same data to prepare to checking enterprise tax risk,identify risks and active ly deal with it, third, The keys of the materia l of the sameperiod are the enterprise risk and profit over the same period data matching, therationa lit y of the selection o f trans fer pric ing method, the effective ness of thecomparable ana lys is three aspects. Fourth, as soon as possib le to apply for advancepricing agreement according to their own situation.