Research On Tax Management Of Transfer Pricing Of Group Cash Pooling

Economic globalization and digital development,global economic development opportunities and challenges,multinational companies are accelerating in the global layout,large enterprise group to maximize the realization of the overall interests,have set up enterprise internal capital pool,more and more multinational enterprises by setting up group pool transfer pricing tax avoidance and huge amount involved,group capital pool transfer pricing problem also gradually caused the attention of the tax authorities and economic cooperation and development organization,the organization for economic cooperation and development issued in recent years to improve the guide pool related transactions,strengthen tax collection and administration.For enterprises,replacing external financing with internal financing is not only lower cost,but also more flexible and convenient to operate.Because the pool involves many laws and regulations,and tax complexity,countries in associated financing transfer pricing also lack of clear laws and regulations,the tax authorities to obtain related transaction information is limited,the lack of system analysis support,difficult to effective comparability analysis and transfer pricing adjustment,will produce a lot of potential risks,the tax authorities on the pool transfer pricing tax management there are many deficiencies.The current tax policy and the management mode of the group’s capital pool still have some incompatibility.This paper focuses on the tax management of the transfer pricing of the group’s capital pool.This paper introduces the relevant theoretical knowledge of the transfer pricing of the capital pool,Summarize the definition and classification of capital pools,On the basis of the internal capital market theory,the principle of independent transaction and the information asymmetry theory,Analyze the current situation of tax management,Combing through policies related to capital pool and transfer pricing,Summarize the main problems of tax management of transfer pricing of capital pools,Analysis of two cases: mainly in group A capital pool transfer pricing management cases,K Oil Company capital pool transfer pricing management case is supplemented,Research on the use of capital pools and transfer pricing,Determine the determination of the interest rate and the income distribution of the leader and the participant;Summarize and summarize the regulations of Australia,the United States,South Korea,Singapore and other countries,the Guidelines issued by the OECD,Analyze the transfer pricing of capital pool,Put forward the policy suggestions on optimizing the tax management of the transfer pricing of the capital pool in China.Based on the above studies,this paper believes that the capital pool of the tax inspection group should weigh the contributions of the leader and the participants and consider the credit rating and guarantee of both parties to determine the interest rate and income distribution,and consider whether there is capital weakening and compliance with the principle of independent transaction.At the same time,a risk assessment system should be built to eliminate the weakening of capital and set up targeted transfer pricing rules.Therefore,China’s tax authorities should establish a scientific information system of fund pool transfer pricing,improve the provisions of laws and regulations of capital pool,standardize the tax collection and administration procedures,comprehensively promote the construction of professional talents,improve work efficiency,and strengthen the international tax information exchange.