我国转移定价税制存在的问题及改进的思考(Thinking about the problem and

我国转移定价税制存在的问题及改进的思考（Thinking about the problem and improvement of existing transfer pricing system

in China）

Thinking about the problem and improvement of existing transfer pricing system in China

The transfer of Chinese thinking problems and improve the existing pricing system of 2008-12-20 15:11:07

With the increasing economic activities of the internationalization of multinational investment in order to seek the advantageous place, have positive outward investment. The tax is different, the objective for the multinational companies provide the premise of international tax avoidance. In the international tax avoidance, transfer pricing is one of the most important means of tax avoidance. In this regard, countries have adopted corresponding measures of anti avoidance, transfer pricing tax system is one of them. The so-called transfer pricing tax system is in accordance with certain principles, through the system and method to adjust transfer pricing in the form of law. Our transfer pricing tax system development started late, in the implementation of exposed some imperfections. In this paper, China's tax system of transfer pricing problems and improvement ideas about some personal views.

The development process of the transfer pricing tax system in our country,

Our country's tax system of transfer pricing in special

economic zones in the practice of anti tax avoidance. Shenzhen city in early 1988 on behalf of the municipal government to formulate and implement the "Shenzhen Special Economic Zone Foreign Investment Enterprises and related company transactions tax management Interim Measures", is actually the first in China's tax system of transfer pricing regulations. On this basis, in 1991 China on Sino foreign joint venture enterprise income tax and income tax on foreign enterprises to merge, in the "People's Republic of China foreign investment enterprise and foreign enterprise income tax law" and its implementing rules specified in the foreign investment enterprises or foreign enterprises and its related business transactions shall pay the price, charges or fees in accordance with the independent enterprise business dealings between. This indicates that China's foreign tax management in the full implementation of the transfer pricing tax system. Since then, China announced in September 1992 the "People's Republic of China tax collection and management law" and in August 1993 published "People's Republic of China tax collection and management law implementation rules" in formulation of the relevant provisions, so as to improve the legislation of transfer pricing tax system in our country. In particular, the State Administration of Taxation in October 1992 according to the "People's Republic of China enterprises with foreign investment and foreign enterprise income tax law" and its implementing regulations, issued the "implementation of enterprises business transactions tax management measures", which greatly enrich the content of the transfer pricing tax system in our country. China's current tax system of transfer pricing for the cognizance of affiliated enterprise, business transactions between independent enterprises, regulating