论转让定价行为的税法规制-法律专业毕业论文.docxVIP

华中科技大学硕士学 位论 华 中 科 技 大 学 硕 士 学 位 论 文 II II Abstract As transnational corporation have been entering Chinese market in large-scale, and a large number of internal transactions occurred between the worldwide affiliates corporations, but that the subjects of market economy abuse affiliate transactions has produced a great deal of illegal affiliate transactions ， they through transfer pricing for illegal tax avoidance, that made transfer pricing issues have become increasingly prominent, moreover, due to there have no perfect transfer pricing system, the domestic company of related party transactions become a hotbed of transfer pricing tax avoidance. In view of the multinational corporation transfer pricing behavior, related experts and scholars have carried on the positive exploration and research on transfer pricing, including qualitative and motivation analysis, methods analysis, the basic principles analysis and the comparative analysis of foreign pricing tax system. This paper one aspect had analysis theories of transfer pricing and transfer pricing tax system, at the same time, introduced the definition of transnational corporation by some countries, classification and the characteristics, and then leads to the related content of transfer pricing, i.e., transfer pricing qualitative, forms and transfer pricing methods, as global concern about the transfer pricing behavior, and many countries have set regulations of tax law on the transfer pricing. This paper mainly introduction the transfer pricing regime of the United States, Japan, and OECD. Based on the analysis characteristics of overseas transfer pricing tax regulation, to clarify Chinese transfer pricing tax system defect, and come up with three aspects suggestions from legislation, law enforcement and compliance law, with a view to Chinas tax system for transfer pricing to achieve the ideal state. Key words: Related enterprises Transfer pricing Tax system PAGE IV PAGE IV 目 录 摘 要I AbstractII