一、融资业务融资业务指公司间借贷、租贷等以债权、债务关系为基础,以利息的支付为代价的资金融通业务。关联公司间的这种业务活动是经常的。了解和掌握其特殊性,对于正确执行转移价格税制是很重要的。 (1)资本投资与借贷关系的认定。作为筹资手段,比较典型的是“增资”和“借贷”(或称举债)。关联公司间特别是母,子公司间,通过母公司对子公司的增资或借贷,都可达到增加子公司资产的目的。前者,母公司取得的报酬是股息;后者,母公司取得的是利息。一般情况下,各国税务当局只承认在借贷关系存在 I. Financing Business Financing business refers to the financing and financing business at the expense of interest payments, such as inter-company loans, leases and loans, which are based on creditor’s rights and debt relationships. This kind of business activity between related companies is frequent. Understanding and mastering its particularity is very important for the correct implementation of the transfer price tax system. (1) Determination of the relationship between capital investment and borrowings. As a means of raising funds, it is more typical of “increasing capital” and “borrowing” (or borrowing). The purpose of increasing the assets of the subsidiary company can be achieved between the affiliated companies, especially the mother company and the subsidiary company, through the parent company’s capital increase or borrowing of the subsidiary company. In the former case, the compensation paid by the parent company is dividend; in the latter, the parent company obtains interest. In general, national tax authorities only recognize the existence of a lending relationship.