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转让定价是跨国公司转移利润避税的一种最常见最主要的方式,反避税工作不可避免地要对转让定价进行调整。三年来,虽然我们已对此作了一些实际的探索,但还有不少值得思考的问题,本文拟就此谈些情况和看法。一、转让定价调整的实践从1988年初开展反避税工作以来,到去年底,我们已对32户外商投资企业的避税行为采取了措施,共核减亏损额1亿元,核增利润额2000多万元。今年1—6月底,结合汇算清缴工作又对40多户外商投资企业进行了这一工作,在一定程度上维护了我国的权益。由于外商投资企业避税的主要手法是转让定价,因此,我们的反避税工作主要是对转让定价的调整。经过几年的实践,我们已在以下几方面形成了一套做法。
Transfer pricing is one of the most common and predominant ways for transnational corporations to evade profits. Anti-tax avoidance work inevitably needs to adjust the transfer pricing. In the past three years, although we have made some practical explorations on this subject, there are still many problems worth considering. We are going to discuss some situations and opinions in this article. I. Practice of Transfer Pricing Adjustment Since the anti-tax avoidance work was carried out in early 1988, by the end of last year we have taken measures against the tax avoidance of 32 foreign-invested enterprises by a total of 100 million yuan of nuclear loss reduction and an additional profit of over 20 million yuan yuan. From the end of January to the end of this year, this work was carried out on more than 40 foreign-invested enterprises in combination with the settlement and settlement work, to a certain extent, safeguarding the rights and interests of our country. Since the main method of tax avoidance by foreign-invested enterprises is transfer pricing, our anti-tax avoidance work mainly focuses on the adjustment of transfer pricing. After several years of practice, we have formed a set of practices in the following aspects.