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• Main Authors: Jung-Chou Lai, 賴榮舟
• Other Authors: Chia-Ying Ma
• Format: Others
• Language: zh-TW
• Published: 2009
• Online Access: http://ndltd.ncl.edu.tw/handle/32442997008273681029

碩士 === 東吳大學 === 會計學系 === 97 === More and more Multinational Corporation have begun to establish their transfer pricing strategy to allocate their operation profits in between properly to minimize their overall tax burden. To prevent such tax evasion behaviors through transfer pricing, many countries recently start to implement related transfer pricing governing laws and re-enforce the auditing of transfer pricing.Republic of China also contains in these countries. Ministry of Finance promulgated the“Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's Length Transfer Pricing”on 28 December, 2004. This regulation, like other tax proposition and reforms, aims to be in compliance with taxation-neutral principal, to maintain a fair allocation of global tax receipts, to eliminate double taxation, and to lower the compliance costs. After the launch of this transfer pricing governing law, some to-do inclusive of lowering un-necessary investment vehicles, minimizing related parties transactions, re-examining related transaction flows, and setup of reasonable transfer pricing policy, are becoming critical for all cross-boarder enterprises. As Market Observation System by Taiwan Stock Exchange (TSE) indicates, up to 2nd quarter of year 2008 all TSE listed companies have recognized a total of TWD 64.6 billion investment income from their investment in Mainland China. Of which this TWD 64.6 billion, those companies within electronics segments accounts for 72% or TWD 46.8 billion. As most of Mainland China investments are made by route of their third-party offshore subsidiaries whose locations are mainly within those tax-free heaven or countries with tax treaty with ROC, accordingly, it becomes easier for these enterprises to flee from heavy taxation by arranging the non-arm length transactions. Our research will take all stand-alone and consolidated financials of all ROC listed companies within electronics segment as data base to study the impact of the implementation of transfer pricing governing regulation and the correlation between transfer pricing regulation with financial reports. Our empirical study matches our prior speculation that a majority of Taiwan cross-border enterprises do try to minimize their tax loading by manipulating transfer pricing in related transactions. And after the announcement of transfer pricing regulation, the relationship between the abnormal trading margin（TP）and the parent company of equity method investment gains and losses not included Pre-tax margin and the consolidated report’s net income before tax which not include equity method investment gain and lose margin difference different number(NEIENI) was a negative correlation. It proves that after the implementation of the transfer pricing regulation the tendency of tax evasion by these enterprises is improved, in view of the auditing risk from Ministry Of Finance. In addition, we use related purchasing amounts to the percentage of operating cost to discuss on Taiwan's transfer pricing strategies of transnational corporations, empirical results show the relationship between abnormal trading margin and the related purchase for the percentage of operating costs was negatively correlated; and related sales amount of the percentage of sales revenue was also negatively correlated, but not appear significant level.It means that Taiwan's use of transfer pricing strategies of transnational corporations to tax evasion, the use of stock price manipulation to achieve the objectives of the possibility of higher sales of some of the less obvious.