论外商投资企业转移定价避税

On the tax avoidance through transfer pricing by enterprises with foreign investment

目前我国许多外商投资企业长期亏损,但仍能够处于非破产境地,其中一个非常重要的原因就是其利用转移定价方式转移利润进而避税,这严重影响了我国的税收征管。本文从外商投资企业转移定价避税的一般表现形式入手,指明我国外商投资企业转移定价避税的特点,分析了现行税收法规对外商投资企业转移定价问题规制的内容及存在的缺陷,提出笔者对于完善相关立法的建议以及其他可采取的一些反避税措施的思考。

At present a lot of enterprises with foreign investment run at a long-term deficit in our country, hut they didn°Фt go bankrupt yet. Concerning it a highly important reason is that they take advantage of the way of transfer pricing to transfer profits so that they can avoid tax, which affects our administration for tax revenue collection seriously. This article, which started with the general display form of tax avoidance by enterprises with foreign investment who utilize transfer pricing, pointed out the trait of tax avoidance by enterprises with foreign investment who utilize transfer pricing in our country, analyzed the defects of the present statutes of revenue on the question that enterprises with foreign investment transfer pricing and put forward the writer＇s suggestion aimed to perfect the related legislation and consideration on the other anti-tax avoidance measures which can be taken.