Research On The Anti-tax Avoidance Of The Transfer Pricing Between Affiliated Enterprises

Transfer pricing is the most commonly used means of tax avoidance of affiliated enterprises.In order to evade tax,both or several parties of the transctions use the transfer pricing,avoiding the limitation of accounting rules and tax law,which damages of the normal market transaction order,thereby affecting the sustainable development of tax revenue and economic health of countries or regions.With the increasing number of Multi-National Corporation and scale is continually expanding,the level and range of affiliated enterprise transfer pricing are continuely expended.which threatens the steady tax revenue.International tax competition have expended from tax revenue levy relationship to the relationship between the government and the state,and upgraded from economic relations to political and strategy level.The anti-tax avoidance legislation in China started fairly late,and experienceis quite scarcity,so the related research and legislation system and maneuverability is not strong.Therefore the associated enterprises how to use improper transfer pricing to avoid tax obligations,and further analyzes our country currently in transfer pricing anti tax evasion limitations,and then explore the crack,improve the tax revenue legal system of our country,strengthen the transfer pricing tax collection and control ability,which to reduce loss of state tax revenue and promote fair tax burden has a important significance and is also the author of the study purpose.This thesis consists of 7 chapters,the research ideas can be divided into four main levels:The first level is the basis of this study,mainly introduces the research purpose and significance,summarizing the domestic and foreign related research results and defining related enterprises,transfer pricing,tax avoidance and anti tax avoidance,which laid the theoretical foundation for the research of this paper.The second level is mainly combined with the common means of tax practice case reveals related enterprises transfer pricing tax avoidance,discusses the current situation and dilemma of China's transfer pricing tax legislation and practice in the field of anti-taxavoidance.The third level builds and analyzes the related enterprises transfer pricing tax avoidance behavior and government tax anti avoidance between static game model,followed by the dynamic extension,revealing objective laws between two parties involved in taxation decision.The fourth level is mainly about some suggestions that are put forward to strengthen the anti tax avoidance work,based on the objective laws.According to the thesis,tax authority should change the current policies to improve the occasion by interference as well as guidance.It is suggested that tax authority strengthen the transfer pricing anti tax avoidance system construction,standardize the information disclosure of related enterprises,prove the advance pricing mechanism,improve the anti tax avoidance information database gradually and train anti-tax avoidance talents,to raise the level of tax collection and management of transfer pricing issues.