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转让定价(Transfer Pricing)是指关联企业之间内部转让产成品、半成品、原材料或互相提供服务、专有权利、秘密配方和资金信贷等活动所确定的转让价格。由于跨国关联企业之间可以利用内部交易所确定的转让价格,把利润的实现地点从税负较高的地区转移到税负较低的地区,从而谋求集团公司内部的整体利益,逃避相关国家或地区的税收管辖。为避免税收权益的流失,各国政府均采取相应措施进行调整,使国家之间、国家与纳税人之间的税收分配关系得到合理的处理。
Transfer Pricing refers to the transfer price determined by such activities as the transfer of finished products, semi-finished products, raw materials or services provided by each other from affiliated enterprises, proprietary rights, secret recipes, and credit facilities. As transnational affiliates can use the transfer price determined by the internal exchange to shift the place of profit from the region with higher tax burden to the region with the lower tax burden so as to seek the overall interests within the group company and avoid the relevant countries or Regional tax jurisdiction. In order to avoid the loss of tax rights and interests, governments of all countries take corresponding measures to make adjustments so that the tax revenue distribution relations among countries, countries and taxpayers are dealt with rationally.