Research On Ir Group Tax Planning Based On Transfer Pricing

Transfer pricing is an important means for multinational company in terms of tax planning.Multinational companies can shift the profit by transfer pricing in connection transaction,so it can change the distribution of the group’s profits and affect the group’s tax burden.But as the G20 in 2013 launched the tax base erosion and transfer of profits(BEPS)plan of action and countries take actively participate in anti-tax avoidance schemes,making it difficult to use transfer pricing for tax planning.Meanwhile,China’s state administration of taxation issued the OECD/G20 tax base erosion and profit transfer(BEPS)project final report in 2015 Chinese version,China’s state administration of taxation issued the OECD/G20 tax base BEPS final report in 2015 Chinese version on October 10 th,2015,indicating that the behavior of using transfer pricing will be restricted,therefore it is important for Multinational companies to use transfer pricing for tax planning reasonably,meanwhile it can achieve the goal that is gaining the most profit and burden the least risk.The paper is researched on IR group.IR group is an enterprise based in Ireland,it commitments to improve the quality of homes,buildings and perishable products and provide the comfortable products,solutions and all kinds of tools for their customs.There is a large internal transaction between subsidiaries within the IR group,which is bound to involve tax issues.When using transfer pricing for tax planning,the premise condition is that companies must have difference tax rate and there is no difference in value added tax in IR group,therefore the paper mainly research on income tax planning by transfer pricing.The paper is based on transfer pricing and tax planning theory.Firstly the paper introduces the basic situation of IR group,the organization structure and business situation,then introduces and analyzes the related transactions and present situation of transfer pricing,next analyzes the present situation of tax planning with transfer pricing and it is concluded that the IR group has the problem that is the use of transfer pricing tax planning problem,including lack of management of tax risk,defect in tax planning based on transfer pricing and there is risk of being contrary to indepent rule,at last the paper puts forward the transfer pricing tax planning model of tax-related risks,and combines the actual business of IR group for tax planning,finally puts forward safeguards for IR group to use transfer pricing tax planning.The safegurds including master the latest international tax law,Establish a transfer pricing tax planning mechanism,Strengthen transfenr pricing related preparations and Find an appointment pricing arrangement.Based on the combination of theory with practice,the paper researched on IR group and put forward for further improvement of transfer pricing in IR group to achieve the aim that makes tax burden reasonable with least risk affection of tax burden.