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内部借款的转让定价涉及资本弱化、资金成本等诸多问题,其方法既要具有合理性,又要具有可操作性。跨国公司的整体运营都立足于全球战略,追求全球利润最大化,可谓“全球一盘棋”。在这种跨国公司内部借款的转让定价中,有一个问题就是对某一笔借款利息的约定是关联企业内部敲定的,为了降低税负,跨国公司极有可能通过调高或调低借款利率,达到降低整体税负水平的目的。跨国公司为了达到降低税负的目的,脱离经营的真实需要,人为扩大负债的比重,相应减少股本投资的比例。如果各国政府对这种情况听之任之,那么跨国公司的资本金将会越来越呈现弱化趋势。
The transfer pricing of internal borrowing involves many issues such as the weakening of capital and the cost of capital. The method of such borrowing is not only reasonable but also feasible. The overall operation of multinational corporations are based on the global strategy, the pursuit of global profit maximization, described as “a global chess ”. One of the problems in this kind of transfer pricing of MNCs’ internal loans is that the agreement on the interest of a loan is determined within the affiliated enterprises. In order to reduce the tax burden, it is very likely that MNCs will raise or lower the loan interest rates, Achieve the purpose of reducing the overall tax burden level. In order to reduce the tax burden, multinational corporations need to increase the proportion of their liabilities and reduce the proportion of their equity investment accordingly. If governments are to hesitate about this situation, then the capital of multinational corporations will be increasingly weakened.