浙江财经学院硕士学位论文
III
ABSTRACT
Transfer pricing is a hot topic of discussion in the field of economy at home and
abroad, in which the principles of fair trade is the basis, however, it is necessary to
compare the controlled transaction and the independent one to apply the principles of
fair trade.In order to bring the comparison make sense, the economic characteristics of
the compared transactions must be fully comparable, so the comparable analysis comes
out. In transfer pricing cases, in order to carry out the necessary comparison with the
fair trade principle, the tax authorities should consider differences with comparable
analysis to determine whether the situation was relatively comparable, and what
adjustments should be done to achieve comparable outcome.At the same
time,enterprises should also consider their various options, make use of the analysis of
comparable transactions, then adjust the differences in order to solve the substantive
impact between controlled transactions and non-controlled transactions between the
substantive impact, so as to constitute a real fair trade.
This article attempts to find practical advice to improve the comparability of the
analysis through the comprehensive theoretical explanation . The full text is divided into
five parts:
The first part is the introduction. First of all, reveal the importanceof the transfer
pricing comparable analysis ,then come out the subject; Second, from both domestic
and foreign research actuality, review of international and domestic research on the
transfer pricing issues; Finally, sums up this paper’s main contents .
The second part is the theory on the basis of comparable analysis of the study.
First of all, according to OECD "multinational companies and tax authorities transfer
pricing guidelines," define the connotation,emphasis on the fundamental principles of
fair trade principle; and then from the five elements of transfer pricing analysis, namely,
the characteristics of the property or services, functional analysis, the terms of the
contract, the economic situation and business strategies,deepen the content.
The third part,discuss the structure of the comparability,divide the process into
extensive analysis, to find the non-controlled trading decisions,select the appropriate
transfer pricing methods and adjustment. This is a continuous cycle process, one or even
a few steps should be repeated to arrive at the best satisfied results. After completion of