Case 1: A multinational company in Betty Loh Ti is headquartered in the United States and has three subsidiaries in Britain, France and China, namely whitehead Company, Searle Company and Double Happiness Company. Wilder company supplies cloth to Searle company in France. Suppose there are 65,438+0,000 pieces of cloth. According to the normal market price of the country where Wilder Company is located, the cost of each piece is 2,600 yuan. This batch of cloth should be sold to Searle at the price of 3000 yuan per piece. Then processed into clothes by Searle Company, and then resold to Shuangxi Company in China. Searle's profit margin is 20%; The tax rates of different countries are 50% in Britain, 60% in France and 30% in China. In order to avoid certain taxes, Jia Multinational Company sold the cloth to Shuangxi Company in China at a price of 2,800 yuan per cloth, then to Searle Company in France at a price of 3,400 yuan per cloth, and then to Searle Company in France at a price of 3,600 yuan. Let's analyze the impact of this on the tax burden of various countries. (1) Tax burden under normal transaction: income tax payable by Huaide Company = (3,000-2,600) ×1000× 50% = 200,000 yuan = 3,000× 20% ×1000× 60% = 360,000. Total income tax payable by Lotte Jia multinational company = 200,000+360,000 = 560,000 yuan (2) Tax burden under abnormal transactions. Income tax payable by Huaide Company = (2800-2600 )×1000× 50% =100000 (yuan )× 60% =120000 (yuan) Income tax payable by Shuangxi Company = (3400-2800) This tax avoidance behavior is mainly due to the difference of tax burden between Britain, France and China, which provides a premise for taxpayers to transfer tax burden by transfer pricing. Case 2: American Shililai Company has two subsidiaries, Wuzhou and Kyushu, in China and Japan. Wuzhou Company made a profit of 30 million yuan that year. According to the fixed dividend rate of 5%, the dividend should be paid to Shililai Company at the end of the year: 30 million× 5% = 654.38+0.5 million yuan; Kyushu Company made a profit of 20 million yuan that year. According to the fixed dividend rate of 4%, the dividend should be paid to Shililai Company at the end of the year: 20 million× 4% = 80 yuan. The governments of China and Japan stipulate that 20% withholding income tax should be levied on dividends remitted to their countries. Wuzhou Company and Kyushu Company sold goods with market value of 4 million yuan and 2 million yuan to Shililai Company at the price of 2.5 million yuan and 6.5438+0.2 million yuan, respectively, instead of paying dividends. Let's analyze the tax avoidance effect of doing so. 1. Tax burden when dividends are paid normally. Tax withheld by Wuzhou Company = 1.5 million× 20% = 300,000 yuan. Tax payable by Kyushu Company = 800,000× 20% =160,000 yuan * * Tax payable: 30+ 16 = Kyushu Company sold the goods to Shililai Company at a low price, from which Shililai Company got a return equivalent to dividends. Wuzhou and Kyushu companies change their payment methods, which is unprofitable. They can evade income tax and do not have to pay withholding tax. Case 3: American domestic tax law stipulates that 20% withholding tax is levied on dividends, interest and other income remitted abroad; French tax law stipulates that 30% withholding tax shall be levied on dividends and interest income remitted abroad. At the same time, in order to coordinate the tax interests of the United States and France, the two countries signed a tax agreement, stipulating that only 5% withholding tax will be levied on similar income between the two countries. There is a loan from a German company, Lai Shide, to an American company, Calina, and Calina pays Lai Shide an interest of 2 million dollars every year. In order to reduce the burden of withholding tax, the company rented a mailbox in France and pretended to be a French resident, and reduced the withholding tax rate of interest from 20% to 5%. This is a way of abusing tax treaties to avoid taxes by mail. According to the normal status of the company in both countries, the interest of $2 million should be withheld by $400,000; After pretending to be a French resident, he only bears the withholding tax of $654.38 million.