中国外资企业转让定价影响因素的分析

The Analysis of Influence Factors on Transfer Pricing of Chinese Foreign Enterprises

鉴于目前中国外资企业转让定价实证研究结论与西方转让定价理论研究结果差距甚远的困惑,文章重新对资料进行了转让定价各因素的相关性分析,得出与以往不同的结论。文章认为,转让定价与外资方式、企业规模无关,而与东道国和母国的税率差异以及国别因素高度相关。这论证推翻了中国外资企业转让定价与税率无关的观点。

Whereas there is significant difference between the conclusions about transfer pricing made by positive study on Chinese foreign enterprises and by oversea theoretical study, this paper analyzes the correlation between factors of transfer pricing and draws a conclusion different from the former ones. It argues that transfer pricing has no relation with the forms of using foreign capital and the enterprise scale, but has a close relation with tax rate differences between host county and home country, and so on country factors. Our argumentation oversets the viewpoint that the transfer pricing of Chinese foreign enterprises has no relation with tax rate.