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| Autor: | Shu-Fen Liu, 劉淑芬 |
|---|---|
| Rok vydání: | 2017 |
| Druh dokumentu: | 學位論文 ; thesis |
| Popis: | 105 In recent years, transfer pricing has been used improperly by multinational enterprise (MNEs) which resulted in tremendous unfair tax avoidance issues around the world. Under global anti-avoidance pressure, the both member and non-member countries of the Organization for Economic Cooperation and Development (OECD) co-participated in drafting the action plans, the 15 separate Action plans of Base Erosion and Profit Shifting (BEPS) had published on October 5, 2015 as a global tax guideline. Many countries are amending their domestic tax regulations accordingly since then, MNEs should plan the transfer pricing strategy to face the upcoming global anti-avoidance actions. Out of 15 action plans, there are 4 action plans related to transfer pricing. In particular, “Action 13 : Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting” is documentation to check the transfer pricing result match the value chain. This action plan gains attention around the world as soon as it published on September 2014. The countries have amended domestic tax law to connect the international tax trend. With the main global countries having implanted BEPS to transfer pricing regulation, MNEs need to be aware of the impact of transfer pricing three-tiered standardized approach to documentation. The documentation reveals a lots of information. This means that MNEs will face more tax challenges and the tax management issues have becomes more urgent and important. This study collected, studied and analyzed the literature concerning the impact of BEPS action plans to the international tax regulations and to explore the risks and challenges to MNEs under BEPS Action 13. And it used a case study to explore the key issues of the new transfer pricing documentation. The conclusions of this study reveal that MNEs should look at the value chain of the group, check each entity’s business model and economic function, evaluate transfer pricing outcomes with value creation. Adjust the investment structure, production and trade process, pricing model and development strategy to improve the transfer pricing strategy. |
| Databáze: | Networked Digital Library of Theses & Dissertations |
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