A Case Study Of Tax Planning Based On Transfer Pricing In Zhuhai Company,A Multinational Group Of MH

The development of transnational corporations is an important driving force and inevitable trend for the continuous growth of enterprises,the optimization of the global division of labor,and the progress of the national and even the world economy.Transfer pricing layout has become an important means to adjust the profit structure,tax burden structure and total tax burden among the subsidiaries of transnational groups.At the same time,the tax authorities all over the world,including our country,have carried out stricter supervision and inspection on the transfer pricing of multinational enterprises.How to actively deal with the new situation of international and domestic taxation,seek the optimal pricing arrangement within the legal and reasonable scope,and realize the maximum profit and minimum tax burden of the group,has become an important financial and tax issue for transnational corporations.According to the theory and the latest laws and regulations of transfer pricing,on the basis of studying the literature of tax planning based on transfer pricing,this paper takes Zhuhai Company of MH Group as the research object,introduces the organizational structure,related transactions,function and risk positioning,value chain positioning and tax planning scheme based on transfer pricing of the group in which the company is located.According to the requirements of the Public Notice of the State Administration of Taxation No.42 of 2016,No.64 of 2016 and No.6 of 2017,the key points of the planning scheme are analyzed,with emphasis on the analysis of reasonable selection of transfer pricing methods,comparability analysis and optimal transfer price decision-making analysis.Finally,according to this scheme,the follow-up thinking and various safeguard measures are put forward.This paper mainly analyzes the tax planning of manufacturing companies based on transfer pricing in the field of tangible assets purchase and sale,strives for small incision in-depth analysis,and summarizes the ideas and key points of MH Group Zhuhai Company’s tax planning scheme based on transfer pricing.It is believed that the planning ideas and arrangements of this scheme are suitable for most manufacturing companies with single functional risk,and multinational companies are encouraged to actively apply for advance pricing arrangements to reduce the risk to a controllable range.This paper argues that the tax planning of transnational corporations based on transfer pricing should also pay special attention to the changes of the internal and external legal environment,pay attention to the incentive management of subsidiaries,and build a good tax-enterprise relationship.