Research On Tax Risk And Countermeasures Of Foreign-funded Enterprises' Related Transactions

With the rapid development of international economy,foreign enterprises have set up subsidiaries in the world,and international trade is becoming more and more frequent.In transnational economic activities,foreign capital business groups utilize scale advantages,unified procurement,unified sales,centralized technology research and development,and make investment plans in the global scope,so as to maximize economic benefits.Through the inter enterprise transfer pricing can achieve the recovery of funds,increase the control,tax avoidance and other needs,to bring a lot of convenience to the enterprise financial planning.Since China's reform and opening up,the introduction of foreign investment has been increasing.Foreign enterprises have made great contributions to GDP growth and tax revenue growth,and promoted the rapid development of China's economy.At the same time,the price of internal transaction is unfair,maybe.Related transactions of foreign enterprises by tax departments concerned,the State Administration of Taxation on strengthening the management of connected transactions,anti avoidance investigation of strength and strength are increasing,the anti avoidance investigation conducted by multinational corporations are increasing in number,involving the tax penalty amount is also growing.Therefore,in the implementation of transfer pricing,enterprises must be aware of this tax risk soberly,and make certain preparations for the risks that may be undertaken.This paper,starting with the theory of transfer pricing,analyzes the forms,causes,consequences and risks of transfer pricing in detail.Take the H company as anexample to illustrate the tax risks faced by the transfer pricing of enterprises.H company is a subsidiary company established by foreign businessmen in our country.The sales of the company are high,but the loss is serious and the profit situation is not ideal.As the raw material of the enterprise is purchased from the affiliated party,the sale of the goods is also completed by its affiliated party,which is a relatively typical internal transaction,that is,the transfer pricing.The tax department tests its related transactions.By finding the financial data of comparable enterprises,it proves that the related transactions of H companies do not conform to the principle of independent transactions,and has made tax adjustments,so the enterprises have paid a huge amount of taxes.Based on the introduction of the tax department's anti tax avoidance work process,this paper analyzes the functions and risks of enterprises in related transaction,explains the corresponding transfer pricing method,and uses transaction net profit method to adjust the profit of target enterprises.Through the case,it points out the large tax risk of the enterprise transfer pricing,and puts forward specific countermeasures and suggestions for the risk.