Research On Transfer Pricing Strategy Of FM Multinational Company

With the rapid development of global economic integration, transfer pricing by the multinational companies more and more attention, gradually become t he inevitable way to its internal trade. For multinational companies, internal connection transaction to the maximum extent for multinational companies to achieve economies of scale, profit maximization conditions, and as the transfer price of related transaction lubricant, its importance is increasingly obvious. In this case, with China's new "enterprise income tax law" and "special tax adjustment measures(trial)" promulgated, and with the in-depth implementation of the measures, formed a relatively comprehensive anti tax-avoidance legal framework and management guidelines, law enforcement for tax authorities and taxpayers to obey the law provides a legal basis, for multinational corporations in China transfer pricing tax adjustments made a comprehensive specification. Facing to strengthen the regulation of transfer pricing in China, multinational companies have to transfer pricing risk into the operation an d management, avoid the risk of transfer pricing by investigation and by adjustment.This paper studies the causes of transfer pricing generated combed transfer pricing management development on a global scale, describes the core principles of transfer pricing and the current major general transfer pricing methods. Finally, select the FM multinationals as a case study to analyze the FM company's business, financial condition, transfer pricing management of the status quo. This paper attempts to analyze specific cases, the first from a company point of view and according to Chinese transfer pricing laws, OECD guidelines, and selects the transfer pricing method, comparability analysis, by selecting TNMM found the arm's length principle in line with the profit range for transfer pricing planning foundation. Subsequently, the analysis focuses on two main issues FM company currently encountered in practice, cum company is high-tech enterprises but do not enjoy the R & D expense deduction and Game Problems also con trol the import regulation and supervision of the tax authorities afterwards.