중국의 다국적기업 이전가격 과세제도 개선방안에 관한 연구

This work primarily presents the problems of the current transfer pricing system of China and operating procedures of tax management based on the transfer pricing system of the US and OECD advanced countries. We suggest that multinational corporations contribute to global economic development while tax avoidance causes tax loss of each taxation authority. Compared with the developed countries such as the US and Japan, the transfer pricing system of China has a lack of systematicity, complementarity of contents, norms and practical operation. So in our work, we suggested that: First, although multinational companies make a significant contribution to the global economic development, at the same time they can have a considerable negative impact on the development of the global market economy through tax avoidance, which causes the tangible tax loss to every tax authority. There are several ways of tax avoidance applied by multinational companies, among them the transfer pricing has been chosen as the main subject of the research since it is the most frequently used by multinational enterprises; Second, the transfer pricing taxation system in China is mainly compiled basing on OECD transfer pricing guideline, but compared with US, Japan, and others systems, while consistency, complementarity of information, norms and practical operations and other various aspects are still can be seen insufficient. So, not only the respective contextual improvement ways but also the reasonable ways for improvement of management of transfer prices taxation system are proposed. Third, we suggested that there is a need to improve the complementarity and normality of contents such as supplementing the regulations of the transfer pricing system and ensuring its effectiveness and supplementing the pre-agreement system. However, it can be pointed out that there may be a difficulty in whether the improvement suggested by the results of this study can be practically carried out.