| Summary: | 碩士 === 中原大學 === 會計研究所 === 92 === 【Abstract】
As global economic development promptly, worldwide tax agencies are trending to audit transfer pricing among Multinational Corporations. The international tax authorities are exercising the regulation as following the provisions of OECD transfer pricing guidelines to fit the current trends.
It is general practice; in order to reduce tax liability most conglomerates manage allocation in normal profit through non-arm's length transactions. However, it may cause illegal and disputing if enterprises take unfair transfer pricing. How to apply transfer-pricing methods legally and effectively is one of the key factors to keep enterprise continuous running.
This research collected different views of domestic and abroad from economic science, mathematic, tax planning, managers’ behavior and empirical analysis on transfer pricing issues. According to the literature review, we can find the transfer pricing goals and major against environmental factors. The empirical tool is questionnaire.
The subjects of this research are Taiwan multinational enterprises that invest in USA, Japan, Hong Kong and Main China on July 2003. In this study, we adopted ANOVA, Chi-Square Test and pair wise multiples comparisons to analyze data. The results reveal that:
1. Transaction activities are affiliated with transfer pricing method.
2. Multinational Corporations adopt different financial benchmark will impact on select trasfer pricing method (TPM).
3. Multinational Corporations confront various environmental factors will impact on select transfer pricing method (TPM).
4. Multinational Corporations respect for various goals will impact on select transfer pricing method (TPM).
There is no constant solution for
Multinational Corporations to set up transfer pricing system. In the opposite, multinational corporations must to manage process depend on the situation to accommodate the changeable environment and targets. This study drew conclusion from empiricism and proposed flowchart of transfer pricing decision for reference. There are nine phases to be recommended for transfer pricing issues. They are including:
(1)Classifying mutual position of transaction for related parties
(2)Defining functional and risk analysis among mutual related parties.
(3)Making sure the goals and benchmark.
(4)Finding maximum environmental limitation
(5)Determining on applicable transfer pricing.
(6)Solving the best transfer- price.
(7)Filing the core of contemporaneous documents.
(8)Conducting transfer pricing program into enterprise’s system
(9)Periodic reviewing transfer-pricing policy.
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