The Application Research Of BEPS Action Plan In Yangzhou National Tax Transfer Pricing Management

In recent years,it has become more and more common that multinational enterprises(MNEs)try to shift their profits by the way of transferring price,which has seriously influenced the tax benefits of many countries.As a result,to prevent globally base-erosion and profit-shifting and allocate profits of MNEs rational,actions of BEPS have been drafted by G20.Drafting actions of BEPS,is a significant way by which countries jointly crack down on international tax avoidance and establish an international tax rules system.It is the first comprehensive remodeling of the international tax rules system in the past century.This thesis firstly introduces the theories of transfer pricing and Actions 8-10 of BEPS,and briefly introduces the actions of China's government to actively promote the action plan.Secondly,introduces the current situation of transfer pricing in Yangzhou,and the difficulties of Yangzhou tax authorities to deal with the transfer pricing problems and analyzes them.Taking the above theories as the breakthrough point,this thesis discusses the latest theories of BEPS action plan,enumerates two cases in practice,shows how the Yangzhou's SAT(State Administration of Taxation)solved the problems of intangible assets and intra-group services in transfer pricing management and how to conduct tax administration,and thus,a conclusion is made.Finally,on the basis of exploring the application of BEPS action plans,this thesis sums up the practical experiences,puts forward some reasonable suggestions on the application of BEPS action plan in Yangzhou tax transfer pricing management from two levels.