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Comparative Analysis of Sino-US transfer pricing

Author: HuangQin
Tutor: LanLan
School: China University of Political Science
Course: International Law
Keywords: Transfer pricing Affiliated enterprises Normal trading principles Compare prices method The comparable profits method
CLC: D912.2
Type: Master's thesis
Year: 2008
Downloads: 295
Quote: 1
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Abstract

With the further development of world economic integration, a growing number of multinational companies in foreign direct investment and the establishment of branches or affiliates. The difference of the tax system of the world, especially the large differences of the rates of all countries, minimum to provide the kind of multinational enterprises worldwide seek tax possible, multinational enterprises to achieve this to reduce the tax burden may be the main way is through the transfer of pricing method. Multinational enterprises to carry out tax avoidance through transfer pricing caused huge loss of revenue to many countries in the world, China suffered the officials of the State Administration of Taxation said that multinational companies an annual tax avoidance caused loss of revenue to 30 billion yuan (36 billion U.S. dollars) or more. Therefore, States have developed the regulation of transfer pricing of the legal system, namely, the transfer pricing tax system, like the United States and other earlier studies of transfer pricing of national regulation and legislation on transfer pricing to obtain a successful experience, our country although also to intensify the transfer pricing regulatory legislation, but due to a late start, there are still many problems. I believe that the transfer pricing system to draw a more perfect system of U.S. legislation, in order to improve China's transfer pricing, and better prepare for the behavior of the Chinese territory of multinational enterprises transfer pricing to evade tax, is bound to increase our taxes, maintenance of state tax revenue equity benefit; help and give full play to the positive role of foreign direct investment to create a tax environment of integrity, and promote the harmonious development of the national economy. This article discusses the total is divided into four parts: Part I: specific interpreting on transfer pricing. From the source of the transfer pricing, motivation, and pricing methods described in this section, and on this basis, the definition of international tax law in the field of transfer pricing, the legal nature of the Analysis. Part II: Overview of Sino-US transfer pricing course of development. The section describes the process of transfer pricing legislation in the United States and China, the core of laws and regulations and bilateral line of a brief introduction. Part III: Sino-US transfer pricing among the laws of the associated enterprises to define and adjust the principle of comparative analysis. The part of them, first of all, a prerequisite for Sino-US transfer pricing - the laws of the associated enterprises defined a comparative analysis, and pointed out the deficiencies of our country. Then a comparative study, and the Abolition of the normal trading principles expounded his views on the principle of regulation of Sino-US transfer pricing adjustment. Part IV: Sino-US transfer pricing adjustment method of the transfer pricing of tangible property which, on analysis. The author in this part of the United States and China compare prices law (including the comparable uncontrolled price method, resale price method and cost plus method) and the comparable profits method (including the comparable profits method, profit split method and transactional net margin method ) the legislative provisions and the advantages and disadvantages of each method were compared, and pointed out our shortcomings and improve the method.

Comparative Analysis of Sino-US transfer pricing

Abstract

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