价格转移ppt.ppt

of 14 ——开发框架的使用和推广 of 14 ——开发框架的使用和推广 Transfer Pricing Introduction Classification Purpose Functions and goals Impact on the country How to react Introduction Over two-thirds of world trade involves multinational enterprises (MNEs). Well over 50% of world trade comprises associated party transactions.? According to Ernst Young Global Surveys（安永全球调查）, transfer pricing is the most important international issue MNEs currently face. Tax authorities around the world are implementing and updating their rules and regulations on international transactions as well as increasing their audit activity（审计活动）. What is transfer pricing? Transfer pricing?is a profit allocation method used to attribute a multinational corporations net profit (or loss) before?tax to countries where it does business. Transfer pricing results in the setting of prices among divisions within an enterprise. Transfer prices are charges for goods and services between controlled (or related) legal entities within an enterprise. 转移价格 是指在跨国公司内部、母公司与子公司、子公司与子公司或联属企业之间相互进行的出口和采购商品、劳务以及其他经营资源内部转让所规定的价格。 What is transfer pricing? Specifically, the subsidiary in a country with high tax rate import goods and materials from its parent company at above-market prices, and then resells the products to the parent company at a very low price. In this way, the subsidiary’s profit is transferred to the parent company. Since the subsidiary seems to be low profit, it is free of the obligation to hand in a large sum of corporate income tax. As a whole, the multinational cooperation’s profit increases. Classification 1、Financing transfer pricing (buy and sell products one another) 2、Tangible assets transfer prices (lease and transfer the internal machinery, equipment and other tangible assets) 3、Intangible transfer pricing (Internal price to provide management, technical and consulting services, trademarks and other intangible goods) Purpose 1、To Implement Global strategy (compete for the market and consumers