Research On Taxation Of Transfer Pricing Of Marketing Intangible Assets

With the development of economic globalization,the openness and inclusiveness of the market economy in our country are expanding.International capital flow has increased.2014,The capital flow of Chinese exceeded the United States for the first time to become the largest country of capital flow.Multinational corporations have entered China in the form of setting up joint ventures,individual proprietorship or affiliates.More and more multinational companies minimize the tax burden by means of transfer pricing because of the complexity of international trade,the difference of tax rate,the imperfection of international tax adjustment mechanism.At the same time,commercial activities such as brand development or market promotion are likely to produce marketing intangible assets.How to confirm and measure the income of the intangible assets belonging to this part of the market,and safeguard the tax benefits of our country,has become a theoretical and practical problem to be solved.The driving role of intangible assets is more and more obvious,the connotation of marketing intangible assets will continue to expand in depth and breadth.The establishment and perfection of marketing intangible assets transfer regulation has become the most complex part of the transfer pricing regulation.The Internal Revenue Service of the United States continues to explore the definition of the scope of marketing intangible assets and the adjustment methods of transfer pricing in order to balance the relationship between tax enterprises and safeguard their own interests.According to the international development situation,OECD formulated the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”(Hereinafter referred to as guidelines).“Guidelines" make appropriate provisions about the definition of marketing intangible assets to guide countries in the transfer pricing adjustment coordination and cooperation.In 2013,“The revised draft discussion on the transfer pricing of intangible assets” provides specific guidelines for the transfer pricing of intangible assets(including marketing intangible assets).In China,there are few researches on the transfer pricing of intangible assets,and the legislation is still in the blank stage.The thesis describes the background and significance of the research,introduces the relevant theories of transfer pricing of marketing intangible assets.The paper combined with the case of Glaxo analyzes the selection and application of the marketing intangible assets transfer pricing adjustment method.At the same time,the paper makes a detailed analysis of the current situation of tax system of Chinese intangible assets transfer pricing.In addition,I have researched the initiatives and perspectives of OECD and other countries about marketing intangible assets transfer pricing in order to provide theoretical reference for the construction and management of marketing intangible assets transfer pricing regulations in china.