| Summary: | 碩士 === 國立中興大學 === 高階經理人碩士在職專班 === 105 === In recent years, the specification of transfer pricing have become increasingly stringent, which means that companies need to establish a tax structure with transactional nature, operational activities and sustainable use. Meanwhile, through the meticulous policies of transfer pricing management, companies can achieve the greatest effectiveness of tax rate optimization. When managing the transfer pricing policies, multinational companies will encounter different country transfer pricing policies and document requirements. If the transfer pricing document planning is not conducted, the process will be more time-consuming, inefficient, and the global pricing policy cannot be integrated. In addition, it will be more difficult for the group to realize the transnational transfer pricing tax risk that it has been exposed to, and therefore, misses the best response time. Hence, multinational companies should develop the integrated global transfer pricing documents and policies based on the parent company or the group. Following the policies of the country where the affiliated companies are located and adjusting the regional pricing strategy accordingly, companies can reasonably allocate the regional profit and further optimize tax risk management.
Facing the international anti-tax avoidance trend, Taiwan has passed new anti-avoidance measures - Controlled Foreign Company and Place of Effective Management. In addition to Taiwan''s new anti-tax avoidance measures, the international anti-tax avoidance is still an ongoing problem. In order to combat tax avoidance, government has continued to introduce new anti-tax avoidance laws and regulations in accordance with the Organization for Economic Co-operation and Development’s (OECD) tax base erosion and profit transfer action plan. In the meantime, the government will also establish the Common Reporting and Due Diligence Standard based on OECD recommendations, in order to prevent transnational tax evasion. Confronting the trend of anti-tax avoidance measures not only in Taiwan but also all over the world, we individuals and multinational companies must be prepared.
In addition to the studies of Chinese and foreign literatures, this study is based on individual cases to analyze the impact of transfer pricing and anti-tax avoidance provisions on multinational corporations. After this study, relevant countermeasures are provided to ensure that multinational enterprises make appropriate tax planning.
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