Research On The Countermeasures Of Special Tax Adjustment Management Under The Background Of BEPS

Under the background of economic globalization,base erosion and profit shifting(BEPS)behaviors of multinational enterprises are becoming more and more intense,which have aroused great concern in all countries.In 2012,the leaders of the Group of 20(G20)entrusted the Organization for Economic Cooperation and Development(OECD)to launch the BEPS Action Plan.In June 2013,the OECD issued the BEPS Action Plan.Faced with such a severe international tax situation,under the background of BEPS,President Xi Jinping has made important instructions on striking international tax evasion on many occasions at the G20 summit,pointing out the direction for special tax adjustment work of China and international special tax adjustment cooperation under the new situation.The State Administration of Taxation has participated actively in the BEPS action plan from the procedural support level,rule making level and work promotion level,and promoted the achievement of BEPS in China in terms of policy formulation and policy implementation.DZ Municipal Office,SAT has also made new progress in the special tax adjustment work,constantly strengthening basic management,strengthening monitoring and management,and carrying out key breakthroughs,contributing to safeguarding our tax rights and interests.However,the special tax adjustment work is facing problems under the background of BEPS,therefore the tax authorities should further strengthen the management of special tax adjustment.The main structure of this paper is divided into five chapters.The first chapter is the introduction,which mainly introduces the background and significance of the research,summarizes the foreign and domestic research results,clarifies the research contents and methods,and then points out the innovation.The second chapter is the theoretical basis of the special tax adjustment management under the background of BEPS.It mainly introduces the concept,characteristics and four kinds of specific tax avoidance means of base erosion and profit shifting for multinational corporation,expounding the category and six management items of special tax adjustment management,and sums up the method and operation process followed in the management of special tax adjustment.The third chapter is the practice of special tax adjustment management in China under the background of BEPS,which begins with the introduction of the basic situation of the BEPS project.This paper summarizes the embodiment of BEPS in China and the progress of special tax adjustment management in China in recent years,and points out five problems in the management of special tax adjustment.The fourth chapter is the examples of special tax adjustment in DZ under the background of BEPS.Based on the collection and management practice of in DZ Municipal Office,SAT,this paper introduces the development about the management of special tax adjustment in DZ in recent years,and then introduces four different types of management cases about special tax adjustment in detail,where we find the experience and the shortcomings in the management of special tax adjustment.The fifth chapter puts forward the countermeasures and suggestions of special tax adjustment management from the three levels of SAT,Provincial Office,SAT,and Municipal Office,SAT,according to the analysis of the defects of Chinese special tax adjustment management,so as to respond to the challenge of BEPS actively.