所得税优惠与关联企业转让定价的关系研究

A study of the Relationship Between Favorable Income Tax and Transfer Pricing Among Affiliates

关联企业利用所得税负的差异，通过内部转让定价避税是税务界和企业界都非常关心的问题。本文运用关联企业内部转移中间产品的理论和同一集团内不同纳税主体间双重征税协调的关系构建出一经济模型，用于分析我国当前税制安排中是否存在对关联企业转让定价避税的激励。

ion: Both the taxation administrations and companies concern about the problem that affiliates use the differences of their income tax burden to avoid tax by manipulating internal transfer prices.This article sets up an economic model which involves the intermediate inputs theory and double taxation exemption coordination among different tax payers in a same group, to analyze whether there are any incentives to avoid tax by affiliates in our country's current tax system.The conclusion shows that current tax system encourages tax avoiding and that misuse of favorable taxing strengthens such effect. At last the article makes some improving suggestions on the basis of the analysis.