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过去二十多年我国经济保持了高速、持续的增长,在吸引外资方面也取得了举世瞩目的成就。外国投资企业为我国的经济快速发展起了很大的推动作用,同时我们也注意到他们给我国经济带来的负面影响不容忽视,在转移定价问题上表现的尤为突出。外国投资企业的转移定价已具有一定的普遍性,严重影响了我国引进外资的关联效应,对我国经济的良性发展极为不利。因此,我国对转让定价的税收立法也显得极为迫切。本文在对跨国公司转移定价的动机,具体做法进行分析研究的基础上,对世界上最发达的资本注意国家美国和富国俱乐部OECD转移定价税制的特点进行了深度剖析,试图找出其中值得我国借鉴之处,由此来推动我国转移定价税制的相关法律法规的制定和完善。
Over the past two decades, our economy has enjoyed rapid and sustained growth and made remarkable achievements in attracting foreign investment. Foreign-invested enterprises have played a very big role in promoting the rapid economic development in our country. At the same time, we also noticed that the negative impact they have on our economy can not be ignored and is particularly prominent in the issue of transfer pricing. The transfer pricing of foreign-invested enterprises has reached a certain degree of universality, seriously affecting the related effects of the introduction of foreign capital in our country and is extremely unfavorable to the sound development of our economy. Therefore, China’s tax legislation on transfer pricing is also extremely urgent. Based on the analysis of the motivation and practice of transnational corporations in transfer pricing, this paper analyzes the characteristics of OECD transfer pricing tax system of the most developed countries in the world and tries to find out which China should learn from. Where to promote the development of China’s transfer pricing tax laws and regulations related to the formulation and improvement.