Research On The Taxation Of Transfer Pricing Of Intangible Assets Under BEPS Action Plan

Under the background of economic globalization,multinational enterprises take advantage of the loopholes in the international tax system,that is,the international income tax rules,to restrict the tax right of the source countries of income,often for the purpose of tax avoidance.The use of the transfer of intangible assets among group members to achieve the purpose of transferring costs to transfer profits,as far as possible to reduce the total tax burden on a global scale.These acts pose a great challenge to the economic sovereignty of individual countries,and to that end.The Organization for Economic Development and Cooperation(OECD)is working on and advancing the tax Base erosion and profit transfer Action Plan(BEPS Action Plan),which was launched by the OECD in June 2013 to combat multiple acts of tax evasion.And endorsed by members of the G20 summit,in order to adjust the loopholes in the international tax system,improve the tax system of international tax agreements and transfer pricing,in order to solve the increasingly aggressive tax planning of transnational corporations.Protect legitimate tax rights and interests of countries.In October 2015,the OECD released the results of the BEPS15 Action Plan,The international tax content and technology are very comprehensive and complex.The ultimate aim of the 15 action plans is to match the tax revenue with the value creation of economic activities.This paper combs and analyzes the latest research results of transfer pricing of intangible assets under BEPS action plan,and makes an analysis of the mismatch between transfer pricing and enterprise value creation,and the contribution of intangible assets to tax revenue is on the high side.In order to protect the tax sovereignty of the countries in the world,especially the developing countries,and to safeguard the tax rights and interests to the maximum extent,the tax revenue of regional special advantage value contribution is not reflected enough,and the tax revenue measurement of cross-border recombination value contribution is complicated.