An Application Research Of Value Creation Principle In Anti-tax Avoidance Of Intangible Assets Transfer Pricing

In the context of a globalized economy,multinational corporations use global loopholes in the global tax system to transfer profits among different countries in order to reduce the overall tax burden on the global scale,thereby reducing costs,and the global economic development of the tax benefits of various countries.All caused great harm.In this process,the tax avoidance method using transfer pricing of intangible assets is particularly evident.Because intangible assets are difficult to measure,their tax management is difficult,and at the same time it can bring huge benefits and rewards to the company,making it intangible.Asset transfer pricing has become a hard-hit area for tax avoidance by multinational corporations.In order to deal with this situation,the OECD,commissioned by the leaders of the Group of Twenty(G20),launched the Action Plan for Tax Base Erosion and Profit Transfer(BEPS Action Plan),which is currently launching Action Plan No.8.It is necessary to formulate relevant rules to prevent tax base erosion and profit transfer caused by the transfer of intangible assets among multinational corporations among various group members.As a big manufacturing country and a major exporter of trade,China has also received the threat posed by the tax avoidance of transfer pricing of intangible assets.Therefore,in addition to actively participating in the BEPS action plan,China has continuously strengthened its intangibility in policy formulation and taxation management.Asset transfer pricing management,through the use of international experience to rationally and legally constrain the tax avoidance activities of multinational corporations,achieves the matching of income rights and value creation of intangible assets,thereby realizing the matching of tax rights and real economic activities to safeguard China's tax rights and interests.Due to the complex fonns of connected transactions of multinational corporations,there is a certain degree of concealment in value creation activities,which makes the tax authorities have many disputes and difficulties in the process of handling cases.This paper adopts a case analysis approach to create value in R&D activities and marketing activities.The object of case analysis discusses the characteristics of tax avoidance by transnational corporations using transfer pricing of intangible assets and how the tax authorities use value creation principles to conduct specific anti-tax avoidance analysis,and discusses the problems and solutions of taxation authorities in the course of specific practical operations.Then,on the basis of the case analysis,we summarized the limitations of the tax authorities when using the value creation principle to carry out anti-tax avoidance work.In the end,this paper combines the development environment of transfer pricing of intangible assets in the world and the latest achievements in the field of transfer pricing of intangible assets in China,and puts forward sound suggestions.