| Summary: | 碩士 === 逢甲大學 === 經營管理碩士在職專班 === 92 === ABSTRACT
In recent years, Taiwanese corporation has been undergoing significant changes in internationalized and globalization. The amount of foreign direct investments by Taiwanese corporations has grown enormously. The stakeholder of the multinational enterprises and their CPAs tried very hard to maximize the global profit by minimize the tax burden.
Tax avoidance will cause secret worry of finance, and lead to negative influence in principle of taxation in reality and fairness. In this environment of diversification, the problems the government may encounter are sophisticated. The international society pays much attention in the field of transfer pricing, anti-tax haven, anti-thin capitalization, and anti-treaty shopping, CFCs, etc. In developed countries, the tax administrations have already enacted new regulations to provide ways, means, scopes, for the cases of international taxation, most of them are following the provision of OECD guideline and the Internal Revenue Code of the United States. Meanwhile, concludes treaties with related countries to prevent the tax evaders from violation by exchange of tax information.
This study is to investigate what may have been absent from the existing regulations of international tax avoidance in our country. The researches on international taxation issues have sprouted since the middle of 1980s. However, the regulations in our country are still inadequate, and need to adopt strategies to deal with the problems. The purposes of this paper are enhancing the Tax Authority of understanding the international tax strategy refer to multinational enterprises and proposing suggestions. I devote special attention to the role played by the CPAs and presented the real cases to examine whether the suggestions made in this study could be of any help.
Keywords：
Multinational Enterprise、Tax Evasion、Transfer Pricing、Anti-Tax Haven、Anti-Thin Capitalization、Anti-Treaty Shopping、CFCs
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