A Comparative Study On The Application Of Transfer Pricing Adjustment Method Under The Background Of BEPS

With the implementation of the international tax reform marked by the tax base erosion and profit transfer(BEPS)action plan in China and the rest of the world,multinationals will face more and more uncertainty in transfer pricing.BEPS emphasized the principle that profits should be taxed in the place where economic activities happen and value creation,which will bring a series of challenges to the operation mode,tax planning and tax compliance of multinational enterprises.With the development of BEPS project,tax authorities in various countries are constantly strengthening tax supervision of multinational corporations,making tax disputes among countries increase,and enterprises are facing a more serious risk of double taxation.The adjustment method of advance into traditional transactions and trading profits,while the traditional trading method including the comparable uncontrolled price method,resale price method,cost plus method,trading profit method includes transaction net profit method,profit split method and comparable profit method.Faced with so many transfer pricing adjustment methods,how to choose,use and improve the transfer pricing adjustment method has become the primary problem facing the national tax authorities.In this paper,through the analysis of seven specific cases of comparison,the traditional trading method between the application of traditional trading method and trading profit method,comparative study of transfer pricing adjustment measures and advance pricing arrangements,it is pointed out that the traditional method of trading in the former method of paying attention to key points and conditions in the process of using and summarizes the traditional transactions,trading profit method and advance pricing arrangements of their advantages and disadvantages,so as to provide the basis for the tax authorities to choose and use the transfer pricing adjustment method.The last part of this paper presents three common problems,set the information in our country at present the transfer pricing adjustment method in the application of the normal trading range sharing and APA scope,aiming at the above problems,this paper combined with the situation of our country to provide the corresponding solutions.