無形資產移轉訂價個案研究

• Main Authors: Meer Liu, 劉小娟
• Other Authors: Yen-pao Chen
• Format: Others
• Language: zh-TW
• Published: 2006
• Online Access: http://ndltd.ncl.edu.tw/handle/34478359084145324255

碩士 === 東吳大學 === 會計學系 === 94 === Cause to the highly development of the economic, cross-border companies use the internal transfer pricing for the related parities. Due to each country has their complex taxation, therefore, provided products and services to the cross-border inter-company’s transfer pricing is more complex than before. The Ministry of Finance (“MOF”) has been announced the Assessment Rules for Non-arm’s Length Transactions by Profit-seeking Enterprises (“Assessment Rules”) for public hearing on December 28, 2004. Pursuant to the Assessment Rules, group companies are required to disclose details of the related party transactions (or controlled transactions) and to prepare sufficient evidentiary documents, e.g. a transfer pricing benchmarking analysis document incorporating functional analysis, economic analysis and the conclusion of whether the taxpayer’s controlled transactions are in accordance with the arm’s length principle etc., ready for submission while filing the annual income tax returns. Compare the OECD, USA intangible property transfer pricing regulations and documents with Taiwan and using the cases study to prove the company used the appropriate transaction-pricing method for the intangible assets.