外资企业转让定价避税与反避税问题探讨（Discussion on tax avoidance and anti avoidance of transfer pricing in foreign enterprises）.doc

外资企业转让定价避税与反避税问题探讨（Discussion on tax avoidance and anti avoidance of transfer pricing in foreign enterprises） Discussion on tax avoidance and anti avoidance of transfer pricing in foreign enterprises Discussion on tax avoidance and anti avoidance of transfer pricing of foreign enterprises 2008-12-20 15:15:38 Abstract: the transfer pricing tax avoidance and anti avoidance of foreign invested enterprises in China is an important topic in the study of tax in our country. Based on the analysis of the current situation of the transfer pricing avoidance of foreign invested enterprises in China, this paper puts forward some measures to prevent the foreign investment enterprises from using transfer pricing to avoid tax. Key words: foreign invested enterprises; transfer pricing; tax avoidance; anti tax avoidance With the deepening of Chinas opening to the outside world, especially after Chinas accession to the WT0, more and more multinational group companies have come into operation in China, striving for Chinas huge potential market. Bring in advanced management experience, talent and technology on the one hand, enterprises with foreign investment to China, to fill the domestic construction funds, the formation and development of the socialist market economy of our country has played a significant role in promoting; on the other hand, some foreign-funded enterprises in order to seek to maximize profits and the minimum tax burden. For a variety of illegal interests in an open way of transfer pricing. Most of Chinas foreign investment enterprises are multinational associated enterprises, and some foreign parent company and related to the existence of a large number of commodity trading, technology, labor, capital and other exchanges, foreign investors by intentionally raising or lowering the price and cost allocation standard, in order to achieve the purpose of tax avoidance. This not only damages the interests of the Chinese investors, the loss of tax revenue of our country,