Research On Anti-tax Avoidance About Intangible Assets Of Transfer Pricing In The Digital Economy

In recent years,the digital economy has maintained a rapid development momentum,which not only innovates people's life styles,but also,under this opportunity,creates a large number of new business models.In addition,even the valuecreating process of traditional industries has been digitally involved.In the process of tax planning,based on the integrated business models,various multinational enterprises gradually pay special attention to the huge potential values of these intangible assets.By means of transfer-pricing,they circumvent taxes of the countries of origin,which intensifies the BEPS problems.In terms of the challenges faced by the anti-tax avoidance,on the one hand,the levels of tax administration information technology lag behind the development of digital economy,on the other hand,many countries have gradually taken unilateral tax measures,such as the digital tax,because of the huge tax erosion caused by transfer pricing of the large-scale intangible assets in digital enterprises.In this way,these countries attempt to directly bypass the international cooperation.In order to increase their tax revenue,new international tax friction has been produced.Therefore,at present,it has become a hot topic in the current research to improve the anti-tax avoidance policy of intangible assets in the digital economy and to form a global consensus goal and achievement.Based on the related research on the economic digital tax challenges and the antitax avoidance of transfer pricing of intangible assets,this paper expounds in detail the impact of transaction virtualization,intangible asset diversification,and user participation inclusiveness on the development of transfer pricing of intangible assets and its anti-tax avoidance in the era of economic digitalization.Meanwhile,on basis of analysis on the reasons why the anti-tax avoidance of transfer pricing of intangible assets produces in the digital economy,this paper takes Amazon,the representative digital company as an example.In this way,from three aspects of the company's organizational structure,the business involved in the transfer pricing of the intangible assets,as well as the cloud computing business,this paper,combined with the background characteristics of the digital economy,explores the new ideas of tax authorities for anti-tax avoidance in the digital economy.On May 31,2019,OECD published "Developing a Work Plan for Consensus Solutions to Answer the Digital Tax Challenges in the Economy".Thereinto,the issues related to the transfer pricing of intangible assets in the digital economy are the revised profit distribution rules and the connection rules mentioned in the work plan,as well as the concept that "New Tax Right" and "Taxable Existence" have been formed.This paper briefly introduces the contents of the transfer pricing of the intangible assets involved in the work plan.In addition,from the perspective of improving the anti-tax avoidance of transfer pricing of intangible assets,this paper carries out a preliminary analysis and expansion.Meanwhile,America has also put forward a marketing intangible asset proposal,and the British's transfer pricing database and other practices have strengthened the anti-tax avoidance strength.This research considers that all the above practices can be used for reference.Therefore,based on the relevant experience at home and abroad,this paper puts forward anti-tax avoidance countermeasures to answer the economic digital challenges from four aspects,including standardizing intangible asset revenue ownership,improving the transfer pricing tax system,and strengthening the tax administration with digital technology as well as promoting international anti-tax avoidance cooperation.