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一、问题的提出新加坡一位资深税务官员曾说过:“跨国公司缴多少税和向谁缴都是他们自己决定的。”这不免有点夸张,但确也反映了跨国公司进行税务规划,特别是通过转移定价逃避税的严重程度。且这种严重性大有愈演愈烈之势。对此,发达国家和发展中国家同样感到头痛。由于发达国家跨国公司的数量多、投资规模巨大,因而当运用转移定价逃避税时,给相关联企业所在国所造成的经济上的动荡和财税方面的流失往往是相当惊人的;而发展中国家由于经济起步晚,法制不健全,危害也相当巨大。例如我国,在《中华人民共和国外商投资企业和外国企业所得税法》(以下简称《新税法》)实施前,有些外商甚至是明目张胆。美国是对转移定价实施管
I. PROBLEM PROPOSALS A senior tax official in Singapore once said: “It is up to them how much tax MNCs pay and who they pay for.” This can be a bit of an exaggeration, but it does reflect the multinational corporations’ tax planning , Especially to avoid the severity of the tax through transfer pricing. And the severity of the situation is getting worse. In this regard, developed countries and developing countries also feel the same headache. Due to the large number of multinational corporations in developed countries and the huge investment scale, economic turmoil and fiscal and tax losses caused by the countries where the enterprises affiliated to the enterprises are often staggering when the transfer tax is evaded are quite alarming. In developing countries Due to the late start of the economy and the imperfect legal system, the damage is also huge. In our country, for example, some foreigners even blatantly blamed before the implementation of the “Income Tax Law of the People’s Republic of China on Foreign-invested Enterprises and Foreign Enterprises” (hereinafter referred to as “the New Tax Law”). The United States is the implementation of transfer pricing management