| Summary: | 碩士 === 國立彰化師範大學 === 會計學系 === 99 === In purposes of lowering costs, enhancing competitive strength and generating group profits, global coverage of various operating activities has been followed by numerous enterprises around the world, which could accomplish cargo, labor and capital transfer and use among different multinational conglomerates through internal transfer pricing. Seeing that and in safeguarding tax revenues, transfer pricing auditing and verification mechanisms are established from country to country to prevent those enterprises from transferring prices and avoiding taxes through associated enterprises. The actual implementation of transfer pricing auditing and verification in our country started from the stipulation of the auditing and verification code of irregular transfer pricing of income taxes of profit-seeking enterprises in 2004, which is relatively late comparing with foreign countries. Under the background of international tax competitions among various countries, the issue of internal trading pricing of multinational conglomerates associated enterprises in purposes of avoiding transfer pricing through associated enterprises being suspected and verified by taxing authorities which resulted in double taxation condition is discussed in this study. Relying on research results of actual cases, the study is also devoted to providing relevant measures which might be carried out by multinational conglomerates in face of transfer pricing among internal associated enterprises.
The following conclusions are reached relying on the results of this study:
1. Positive transfer pricing notion should be built and internal transfer pricing strategies should be established by onshore controlling multinational conglomerates.
2. Reasonable profit distribution will be arranged in transfer pricing strategies in advance in accordance with the operating models of the group and the functions executed and risks undertaken by various regional organizations inside the group, that is, so-called [Prevention Is Better than Cure].
3. Fully prepare relevant indenture materials and reasonable business reasons for transfer pricing among multinational conglomerates associated enterprises.
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