选址节约理念在转让定价管理中的应用与挑战

Application of Location Savings in Transfer Pricing Administration and Its Challenge

近年来,选址节约成为我国税务部门高度关注的一个重要转让定价问题,也是应对跨国公司税基侵蚀与利润转移的反避税新理念。本文结合汽车制造业的案例,运用"四步法"阐述了对选址节约进行转让定价调整的理论基础和实务操作,并对选址节约理念在新兴经济国家转让定价管理中的挑战进行了分析。

In recent years, location savings has been a critical issue in transfer pricing highly concerned by tax authorities in China, which also become a new concept to cope with tax base erosion and profit shifting of multinational companies. By considering the case of automobile manufacturing, the paper utilizes＂Four-step Approach＂ to state the theoretical basis and practice for transfer pricing on location savings, and then analyzes the challenges faced by the concept of location savings in the transfer pricing administration in emerging economies.