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目前,我国三资企业中,进口设备、原材料高报价,出口成品、半成品低报价的现象普遍存在且非常严重。从这一高一低中,外商通过价格这一工具,将利润大量转移出境,逃避国家税收,很多企业在帐面上一直处于亏损局面。其实,这一现象在世界范围内普遍存在,它不仅仅是中国与外商的关系问题,而且也是全球范围内东道国与跨国公司的关系问题。三资企业在各个国家的大量出现,是跨国公司在全球范围内发展的必然结果。实质上,各国境内的三资企业都是跨国公司集团内的成员,即分支机构。三资企业所进口的原材料和机器设备,绝大部分来源于集团内中的母公司或其他子公司,三资企业出口半成品和成品,往往也是直接供给其海外国公司或其他子公司满足其生产需要,或由其进行销售。也正因为如此,三资企业中的外商便可利用“高进低出”进行利润转移。因此,对于我国三资企业中的“高进低出”现象,我们必须站在整个跨国公司的高度来认识、分析和研究,掌握其规律性,才能采取相应对策,限制其对价格的操纵,弱化价格在利润转移方面的作用。为此,本文就跨国公司内部交易形式和转移价格的形成、转移价格的基本功能及其派生效应、限制转移价格作用的主要途径等问题进行一下探讨。
At present, in China’s foreign-funded enterprises, the high quotation of imported equipment and raw materials and the low quotation of finished products and semi-finished products are widespread and very serious. From this high and low level, foreign companies have shifted their profits out of the country by means of price as a means of evading national taxes. Many companies have been losing money on the books. Actually, this phenomenon is widespread in the world. It is not only the issue of the relationship between China and foreign investors, but also the issue of the relationship between the host country and transnational corporations on a global scale. The emergence of a large number of foreign-funded enterprises in various countries is the inevitable result of the development of transnational corporations on a global scale. In essence, foreign-funded enterprises in various countries are members of a multinational corporation group, that is, branches. Most of the raw materials, machinery and equipment imported by foreign-funded enterprises come from the parent companies or other subsidiaries within the group. The foreign-funded enterprises export semi-finished and finished products, often directly to their foreign companies or other subsidiaries to meet their production needs. Needed or sold by it. It is precisely because of this that foreign investors in foreign-funded enterprises can use “high-income and low-output” for profit transfer. Therefore, for the “high-income and low-income” phenomenon in China’s foreign-funded enterprises, we must recognize, analyze, and study at the height of the entire multinational company, grasp its regularity, and take corresponding measures to limit its manipulation of prices. Weaken the role of price in profit transfer. For this reason, this article discusses the formation of transnational companies’ internal transaction forms and transfer prices, the basic functions of transfer prices, their derivative effects, and the main ways of limiting the role of transfer prices.