转移定价新论

New Viewpoints on Transfer Pricing

转移定价的核心问题在于,转移定价作为旨在提高企业效率的经济激励工具,与出于纳税征税目的的计算方法,是有重要区别的。前者着眼于、服务于使企业集团整体利润、利益最大化,后者则着眼于、服务于跨国企业的税收负担最小化。随着经济全球化与知识产权对经济的渗透,二者之间的紧张关系也在加剧。这正是转移定价问题近年来本身剧烈动荡,酝酿着变化与变革的根本原因。

The core issue of transfer pricing is that there is a big difference between transfer pricing as a tool of economic incentive for enhancing enterprise efficiency and as a computing method for taxation. The former serves to maximize the overall profits and benefits of enterprises, and the latter serves to minimize its tax burden. With the infiltration of globalization and intellectual property to economy, the tension between the two has been heightened. This is why transfer pricing has been in ferment with changes and reforms in recent years.