New Development Of Transfer Pricing Rules For Intangibles And Its Impact On China

Transfer pricing issues related to intangible properties have become one of the key and difficult points that the international tax law focuses on.The final report of BEPS Action 8-10 issued by OECD(Organization for Economic Co-operation and Development)proposes many improvements of transfer pricing rules for intangible properties.The contents and notions included in the report will have a far-reaching and profound influence on the development of the transfer pricing rules for intangible assets.This thesis compares transfer pricing rules for intangible assets proposed by BEPS Action 8-10 with those included in 2010 OECD Transfer Pricing Guidelines,and analyzes the development of transfer pricing rules for intangible assets.The thesis covers the definition of intangible assets and the principles and approaches that transfer pricing rules for intangible assets should follow.Then evaluations of proposals for the development of transfer pricing rules regarding intangible assets in BEPS Action 8-10 are made based on the principles of fairness,efficiency,and neutrality,and the impact on anti-tax avoidance,analyzing the progress and weakness of the Action 8-10 according to the principles and goals of international tax law.Finally the author analyzes existing transfer pricing rules for intangible assets and their proposed revision in China,and submits suggestions on the future development of transfer pricing rules regarding intangible assets in China,considering proposals in BEPS Action 8-10 and the reality of Chinese economy and society.