I. Background of the case

In the early days of reform and opening up, there was still some resistance in the process of planned economy transformation, so the macro policy was put forward

It is said that "openness can introduce technology and management", which is also to break the resistance. As a result, foreign-funded enterprises have obtained

Preferential policies in taxation, land, etc. However, many foreign investors use this as a way to obtain excess returns.

A research on foreign capital completed by the research group of "Utilization of Foreign Capital and Enterprises with Foreign Investment" of the National Bureau of Statistics.

According to the report, about 2/3 of the foreign-invested enterprises with losses are abnormal losses, and they avoid taxes through transfer pricing every year.

The tax loss is 30 billion yuan. Foreign-funded enterprises can open at lower prices by virtue of super-national treatment and tax avoidance.

Expanding and occupying the domestic market has produced a huge crowding-out effect on domestic enterprises.

Studying the behavior of multinational companies in China can also provide experience for China enterprises. Grouping and globalization are the development of enterprises.

Exhibition trend, China enterprises will encounter quite a few problems in this process, learn from excellent multinational companies,

Strengthening the management and control ability of parent and subsidiary companies is the only way for China enterprises to succeed.

II. Profit Transfer of Multinational Corporations-Successful Horizontal Control

In the process of globalization of multinational corporations, under the guidance of the overall framework of management and control of their parent and subsidiary companies, out of the group

Overall strategic considerations, for its many subsidiaries in different business areas and different regions, the parent company will be rooted.

Construct effective horizontal control according to the change of operating environment. With the assistance of financial control, the overall strategy of the group

Implementation will be faster and more effective.

1.Motivation of profit transfer of multinational companies-transferring profits belonging to China to its group.

There are many ways for multinational companies to establish subsidiaries in China, which can be generally divided into Sino-foreign joint ventures and foreign investors.

There are two kinds of wholly-owned companies. In Sino-foreign joint ventures, Chinese partners are not included in the group's interest map, no.

Is a part of the group, then the mother-child control system of multinational companies will naturally involve how to make it in Huazigong.

Division can create more profits for the group. Under the condition that the profits that the joint venture company can create are fixed, according to the joint venture

In the company, both parties share the benefits and risks, and the horizontal control generally established by multinational companies will require finding ways to

The overall profit of the joint venture company shall be transferred to the parent company or a wholly-owned subsidiary as far as possible, so as to realize the maximum benefit of the group.

Change.

We just mentioned the strategic reality that multinational companies control the profits of their subsidiaries to maximize the profits of the group.

In fact, it is a horizontal strategy in the management and control of parent-subsidiary companies. Horizontal strategy (horizontal1strategy) is to coordinate related industries.

The objectives and strategies of business units, including coordinating existing business units and choosing to enter new ones based on the association with existing units.

Industry. Horizontal strategy is the coordination and unification of the objectives and policies of the headquarters of the group company to its subordinate business units.

So what is the way to make such horizontal control effective?

2. Ways to transfer profits of transnational corporations

To implement effective horizontal control, multinational companies need to think about all kinds of benefits in cooperation

Your own opportunities, and the use value of opportunities. It is not enough to have a strategy for horizontal control, but also to have operable tools.

Body strategy. Multinational companies in China implement the horizontal control strategy of profit transfer, which is nothing more than the following two strategies:

(1) Use brand advantages to clamp down partners.

Chinese enterprises in joint ventures often do not have their own brands, but expect to use the knowledge provided by multinational companies.

Famous brands quickly increased their sales and seized the market. In the joint venture, this practice can really increase sales quickly.

However, it has also established China's dependence on foreign investors. Without the well-known brands provided by multinational companies, China can hardly.

Survival. Based on this, multinational companies have taken the initiative in the operation of joint ventures, and China has to look at it.

Act with a face.

Simply restraining partners can not bring direct benefits to multinational companies, and it is very important for their horizontal strategy

There is no direct impact on the implementation of the joint venture, and multinational companies must further master the financial control of the joint venture in order to be real.

Transfer of cash profits. So how did the financial dominance fall into the hands of multinational companies?

(2) Take advantage of technology to master the purchase and sale channels.

In many joint ventures, China has more controlling shares, and it is reasonable to say that it should be China that holds the leadership.

Enterprises, but in practical work, because foreign capital provides "advanced management experience" and "advanced production technology

",mastered the decision-making direction of most practical problems. In particular, the foreign party relies on technical control rights to actually operate.

Control the purchasing power of raw materials and parts.

In addition, as a condition for the establishment of a joint venture company, multinational companies actually have most of the sales rights of the group.

When it comes to buying and selling, it will inevitably involve finance. The result of purchasing is cash outflow, and the result of sales is cash flow.

This provides the possibility for the profit transfer of multinational companies.

The profit transfer of foreign-funded enterprises occurs in the procurement process, and its premise is that the foreign party adheres to the "original supply principle".

In a Sino-foreign joint venture host enterprise or vehicle enterprise, the foreign party has mastered the raw materials and spare parts by virtue of the technical control right.

Purchasing power. In recent years, Sino-foreign joint ventures and wholly foreign-owned enterprises have generally insisted on purchasing raw materials and parts.

"Original supply principle" excludes Chinese-funded enterprises.

Take automobile production enterprises as an example, foreign investors deliberately set up wholly-owned parts enterprises in their own countries, and they are setting up in China.

Foreign joint venture vehicle company. A part of the money earned by a Sino-foreign joint venture company should be distributed to the Chinese side, but foreign investors should set up in their own countries.

The profits earned by the wholly-owned parts company are entirely foreign. China spare parts enterprises to Sino-foreign joint venture host enterprises and

Vehicle enterprises supplying supporting products must pass the "certification" of the foreign headquarters. In this way, "profit transfer" has been realized.

"Certification" is just a means, and transferring profits is the essence.

Purchasing raw materials and spare parts from the parent company at a high price is another magic weapon for foreign companies to "steal the column". the whole family

Japanese auto parts companies purchase raw materials from their parent companies, and their purchase prices are dozens higher than those of the same raw materials in China.

Times. An authoritative source told the reporter that the foreign party purchased raw materials and parts from the parent company at a high price, and then purchased them from the parent company at a low price.

Selling products, thereby transferring profits to the parent company, increasing the cost of Sino-foreign joint ventures and reducing Sino-foreign joint ventures.

The profit of the industry.

From the group strategy, to the horizontal strategy, and then to the specific operational strategy, multinational companies have shown horizontal control.

The effectiveness, the development strategy of its subsidiary in China has long been included in the overall strategy of the group, until the Chinese side realizes.

When it comes to this question, it seems that everything is unshakable.

III. Tax Avoidance Analysis of Multinational Corporations-Strong Financial Control

In the parent-subsidiary management and control system, financial management and control is undoubtedly the most concerned, because financial data.

Indicator is an important symbol of the success of parent-subsidiary management, and it is also the core of parent-subsidiary management.

The centralized management of the parent company is based on financial mastery of the following rights:

(1), the parent company's final decision-making power on the investment and income distribution of its subsidiaries;

(2) The parent company has the right to regulate the accounting of its subsidiaries, and the subsidiaries implement the unified accounting system and meeting of the parent company.

Planning policy;

(3) The parent company has the right to regulate the financial affairs of its subsidiaries.

1.Motivation of tax avoidance by multinational corporations ―― Tax loopholes caused by super-national treatment

Before making reasonable financial control, multinational companies will first study the national conditions in the country and, according to specific circumstances,

Make an analysis and build a suitable financial management model in combination with the development strategy of the enterprise.

The Income Tax Law of the People's Republic of China on Enterprises with Foreign Investment and Foreign Enterprises stipulates that for productive foreign investment

A foreign-funded enterprise with an operating period of more than 10 years shall be exempted from enterprise income from the first profit-making year and the second year.

Tax, corporate income tax will be halved from the third year to the fifth year.

For these enterprises, there are two ways to avoid paying taxes: one is to lose money, but only to make profits for two years.

Multinational companies may not adopt the above-mentioned business methods, and multinational companies have specialized lawyers to study the politics of various countries.

Policy, as well as policy loopholes, combined with various cost analysis, to make a very legal and reasonable financial control, with

The implementation of horizontal strategy.

2. How do multinational companies avoid tax?

In the process of studying the tax avoidance methods of multinational companies in China, we found that their strong financial control is very good.

In line with the overall strategy and horizontal strategy of the group, with its global integrated financial management and control system, they have formulated

The tax avoidance scheme can be implemented smoothly. So, what specific methods do they use to avoid taxes?

(1) price transfer

From the problems found in practice, there are several ways for enterprises to evade taxes: first, cross-border

In terms of trade, profits are transferred to enterprises in the tax reduction and exemption period through over-reporting of exports and under-reporting of imports, or through

Under-reporting of exports and over-reporting of imports make foreign-invested enterprises that have passed the tax reduction and exemption period in a state of loss or meager profit. Jiuqian

Generally speaking, enterprises evade overseas taxes, which is not the focus of China tax authorities, but it is often washing.

An important channel for money or hot money to flow into China. As far as the latter is concerned, it damages the tax base of China; In the global economy

Under the general trend of globalization, this widely used means by multinational enterprises should become China customs and taxation

The focus of the department.

For example, a food company in Hebei, the domestic price of its main products in 2005 was 7 1 yuan/box, but the export price was 71box.

Only 36 yuan/box; A pharmaceutical company in Shandong will export its products through direct pricing by its overseas parent company.

The unit price is set to be lower than the average price of similar products in China by 40 yuan, so as to reduce sales revenue and disguise actual profits.

Transfer out of the country Under the current situation, the above-mentioned behavior of enterprises will not only become a channel for capital flight, but also cause the country

The loss of tax revenue will also become one of the excuses for foreign countries to accuse China of dumping at a low price.

Secondly, in service trade, foreign-invested enterprises share management fees, consulting fees and technology patents.

Transfer payment of fees can achieve the purpose of transferring profits to domestic or overseas enterprises. For example, Hebei Yi Ceramics Co., Ltd.

The company signed an agreement with its parent company in Hong Kong, stipulating that 32% of its sales revenue should be paid overseas for consulting every year.

Fee, in 2005 alone paid $8.04 million, equivalent to three times its profits that year. Shenzhen No.1 Petrochemical Company Limited

Division, from 2003 to 2005, paid technology transfer fee, service fee and trademark license fee10.6 billion to overseas affiliated enterprises.

Yuan, accounting for 56.3% of the total management expenses, accounting for 63% of the uncompensated loss of 260 million yuan. The proportion of its service trade expenditure

The height is really staggering.

Multinational companies in China obviously use price transfer as the main means to realize profit transfer and tax avoidance. Zaimuzigong

Among the characteristics of financial management and control, we notice that enterprise groups are highly comprehensive in financial management.

Budget, budget structure and operation process are more complicated. Multinational companies obviously know this well, and their actual operation methods

It is very complicated, and it often turns better abroad, and the internal financial accounting has a very advanced software system.

Some software systems are difficult for domestic tax workers to operate at all, so it is extremely difficult to supervise them.

(2) capital weakening-the channel of false losses

In terms of capital account transactions, enterprises can not only transfer shares or register shell companies, but also

The registered place of the parent company is changed to an offshore financial center and other tax preferential areas, and the profits are transferred to

Parent company; You can also remit debt interest as much as possible by increasing shareholder loans and weakening capital.

Reduce pre-tax profits. The international economic cooperation organization's criterion for capital weakening is that the ratio of enterprise equity to debt capital is low.

On 1: 1, the recognition standard of American tax system is 1: 1.5. According to the current tax law of China, enterprises should borrow foreign debts.

Interest payment can be deducted from the enterprise's pre-tax income.

In order to achieve the purpose of tax avoidance, some foreign-invested enterprises borrow as much as possible from shareholders' loans to transfer their rights and interests.

The ratio of capital to debt capital is much lower than the international standard of 1: 1, so as to cause book entry by means of capital weakening.

Losses, while the actual profits are remitted to the overseas parent company through debt interest.

In addition to the weakening of capital, there are still many foreign-invested enterprises that remit their actual income through price transfer.

Enterprises registered in tax-avoidance offshore financial centers, while domestic foreign-invested enterprises themselves have been in a state of loss for a long time.

In the financial control system of parent-subsidiary company, fund management is an important content. In order to obtain

To get more funds for the development of enterprises, it is almost the only way for every enterprise to borrow from banks, but banks

However, the interest on loans has caused the financial expenses of enterprises to rise sharply. Even joint-stock enterprises, through the open market

Market to raise a lot of money, but in the face of the capital market, but there is still a return on investment.

Although the interest generated by borrowing in China can also be deducted from the pre-tax income of enterprises, instead of paying the interest.

For domestic banks, it is better to pay the parent company at a higher interest rate, and at the same time achieve the purpose of tax avoidance and profit transfer.

Yes.

(3) The new foreign enterprises are the carriers for the old foreign enterprises to evade taxes.

Overseas investors shall set up new foreign-invested enterprises in a rolling manner according to the time period of two exemptions and three reductions, and pass through the territory.

Related party transactions between domestic, new and old foreign companies or between domestic and foreign companies make the old foreign companies lose money and the new foreign companies gain money, which is another.

A means of evading taxes.

For example, a well-known Taiwan-funded food group has a trend of increasing foreign-invested enterprises according to the tax reduction and exemption period.

The series of Taiwan-funded enterprises have made a lot of profits in the first two years after their establishment; In the three years when the tax revenue is halved, the profit will be significantly lower.

Slippery; After paying taxes in full, it will immediately fall into a critical point of profit or loss. And adjust the benefits of new and old foreign-invested enterprises

There are also related party transactions mentioned above. For example, Qingdao-Korea Shoe-making Co., Ltd., through overseas mothers

Companies manipulate import and export prices, and let old foreign companies bear the extra costs of new foreign companies, so that old foreign companies can grow all the year round.

Loss, the profit rate of new foreign companies is extremely high. The return on net assets of the group's enterprises during the tax preferential period was as high as

757%, which is in sharp contrast with the sustained losses of old foreign companies with the same business scope.

As we mentioned earlier, multinational corporations have specialized lawyers to study the laws of the countries where their subsidiaries are located.

However, China's current institutional defects in introducing foreign capital have become a link for multinational companies to use. For many local officials

For officials, the introduction of foreign capital is equivalent to political achievements, so when introducing foreign capital, we do not pay attention to the benefits that foreign capital can bring.

On the other hand, we have seen another manifestation of foreign capital horizontal control in China. For the Group,

It is better to transfer profits from one country to another and taxes abroad than to transfer them within a country.

It is convenient and cheap to move, and it ensures the capital demand when reinvesting in the country where the subsidiary is located. Lateral controlled

The content is very rich.

4. The reference of parent-subsidiary management in the process of enterprise collectivization and globalization in China.

The formulation of strategy is the extension of strategy formulation, and we think that the formulation of a set of strategies and strategies of multinational corporations

And the reason why the management and implementation can be so thorough and smooth is inseparable from its perfect management and control system of parent and subsidiary companies. step

Chinese companies don't just transfer profits and avoid taxes in China for the special situation of China, but in all corners of the world.

Fall, as long as there is interest, as long as it is within the scope of its group business, their parent-subsidiary company control system will be implemented.

With the influence, its excellent horizontal control and financial control are like the merger of two swords, which is unbreakable.

For enterprises in China, collectivization and globalization are inevitable trends. Without such ambition, it will be

However, it will lag behind other enterprises. In order to be collectivized and globalized, it is necessary to strengthen the control of parent-subsidiary companies.

How to strengthen the control of parent-subsidiary companies? Enterprises in China are not without experience to learn from, multinational companies in China.

Many cases have become living textbooks. Let's ignore the profit transfer and tax avoidance of multinational companies in China for the time being.

Whether these two practices are correct or not, at least in terms of horizontal strategy and financial control, there are many things worth learning from China enterprises.

The place.

1.Horizontal strategy of the Group

(1) How to understand the horizontal strategy?

Horizontal strategy is to coordinate the objectives and strategies of related business units, including coordinating existing business units and coordinating related business units.

The association of existing units chooses to enter new industries. Horizontal strategy can and should be at the level of group, department and company.

Second existence. However, no matter how carefully enterprises make strategies for individual business units, they only have the most

Informal horizontal strategy. However, visible correlation is still the main potential source of competitive advantage. transparent

Horizontal strategy should be the core of group, department and company strategy.

Without a clear horizontal strategy, it is difficult for enterprises to resist the persistent problem of maximizing the performance of a single business unit.

Strong pressure to damage the performance of companies, especially those with a tradition of decentralized decision-making.

Multinational companies do not limit their advantages to a single department or a single geographical area, but

Measure the scientific nature of the strategy from the perspective of maximizing the interests of the group.

Horizontal strategy is the concept of group, company and department strategy based on competitive advantage, but it is not.

It is business portfolio management, which is the essence of company strategy.

Horizontal strategy is the coordination and unification of the objectives and policies of the headquarters of the group company to its subordinate business units. In many

In group enterprises, there are long-term strategic correlations. Identify these correlations and obtain them.

The strategic benefit is the difference between the group company and the multi-enterprise consortium.

The horizontal strategy is that the headquarters of the group company realizes the synergy between subordinate business units through associated management.

In the case of collectivization, create a competitive advantage for subordinate enterprises that can never be achieved as a single enterprise to enhance the group

Company management and control level.

China enterprises should gradually get used to the overall consideration in the process of collectivization, and don't care too much about a certain

The key to the temporary success or failure of a field or region is to maximize the interests of the group through a reasonable horizontal strategy. that

Yao, how should we formulate a horizontal strategy?

(2) the formulation of horizontal strategy

I. identify the association. First, it is necessary to scientifically identify the actual existence or

All the potential tangible horizontal relations. In practice, the first step is to check the value chain of each business unit.

Whether there are practical and possible opportunities to use various value activities. At first, we should be aware of everything that seems to exist.

Identify the horizontal relationship; Then, through further analysis, eliminate those illusory or meaningless horizontal.

Relationship. When studying the horizontal relationship, we must understand the specific characteristics of the value activities that may provide the basis for the use of * * *

To identify.

Ii. assess the relevance, if the benefits of transferring know-how outweigh the costs of transferring know-how, intangible mutual

Relationships lead to competitive advantage. If there are many similarities between value activities, the competition between value activities and related industries

If the advantage is very important and the transfer of the company's expertise can enhance the competitive advantage materially, then transfer the expertise.

It is a beneficial activity.

Iii. Develop a horizontal strategy. If the company does not have an incentive to coordinate and transfer skills between business units,

The horizontal organization mechanism can not successfully develop interconnection. Determine the appropriate business units and make them into phases.

Should be the group and department, as well as the establishment of incentive system to encourage managers of business units, and so on.

Shi, these are crucial to the success of the enterprise.

The foregoing is the general formulation process of horizontal strategy, and the group company must recognize when formulating horizontal strategy.

Know your own parent-subsidiary control system, and you can't leave the parent-subsidiary control framework.

2. Financial control of the Group

From our previous analysis, we can see that the implementation of the horizontal strategy of multinational companies needs the allocation of group financial control.

Close. For financial management and control, enterprises in China are no strangers. No matter how small enterprises are, they also need financial management.

Reason. However, the scale of enterprises is different, so are the requirements of financial management. Then the financial management of group companies

What are the requirements of control? How to implement financial control?

(1) Requirements for financial control

The most ideal financial management and control system of parent and subsidiary companies should not be too dead, and should not be too open and feasible.

Effective control system.

The key part of group financial management is to combine strategy, business plan and budget management, which also

It is the most important means of strategy implementation and implementation.

A sound financial analysis and reporting system is an effective means to implement management and control, and it also supports the top management of the group.

Important information basis for leaders to make decisions.

Reducing financial management costs is an important indicator to measure a company's management level and operating mechanism.

Observing the financial control system of multinational companies in China, we can find that their financial control system is to focus on

Focus on the efficiency and cost of financial control and the effectiveness of coordination strategy.

(2) How to implement financial control

I. Improve the financial system

If the accounting system is not perfect, it will give operators the opportunity to violate the law and discipline. The accounting system is ex ante.

Prevention, accounting is in-process and immediate supervision, while auditing is post-event supervision. Enterprise finance in a certain period

The confusion of management system and the low financial control ability are often the main reasons for the financial failure of an enterprise.

ⅱ. Financial budget control

Through the preparation of financial budget, the group company can fully grasp the production and operation process of its subordinate enterprises. Financial budget

After the calculation is issued, it becomes the company's business goal, and it generally does not need to be adjusted during implementation. Special circumstances need to be adjusted

Yes, it should be reported to the board of directors for approval in accordance with the procedures. Through the dynamic management of the financial budget, the group headquarters can help the company

The main financial activities of the company and its branches shall be effectively controlled.

ⅲ. Effective control of cash

First of all, we must put an end to off-balance-sheet cash circulation, and all cash must enter the bank account system. The second is to ensure

All cash can be managed centrally. An enterprise can set up a financial settlement center to manage the funds within the group in a unified way.

Management, timely understanding of subsidiary funds operation direction. The third is to do a good job in budget settlement. Daily expenses should be paid in advance.

Budget, with settlement afterwards. Fourth, expenditure items exceeding a certain amount must be approved by the board of directors. The fifth is the capital.

Unified raising, so as to directly control the operating investment plan, and make important decisions such as fund allocation and profit distribution.

Direct control and centralized management.

Ⅳ. Control over the assets and liabilities of the enterprise

Assets and liabilities are important indicators to measure the operation quality of enterprises. The investor gives the right to operate to the operator.

Internationally, the two powers are separated. This requires investors to strictly control the assets held by operators, and when purchasing,

File for approval, record the file when scrapping, and assign a special person to check the accounts and materials.

Because excessive debt can lead to the destruction of capital, investors must rationalize the debt.

The scale of constant control. Investors' liabilities will generally be related to banks, so deal with them properly.

The relationship between creditor's rights and debts is the main means to control the assets and liabilities of enterprises.

ⅴ. Financial risk control

Financial risk refers to the uncertainty of enterprise income caused by debt. Enterprise debt management will have a great impact on enterprises

The profitability of the funds is affected, and the debtor has priority over the assets of the enterprise because the liabilities have to pay interest.

Rights, in case of poor management of the company, or other unfavorable factors, the company is insolvent and in danger of bankruptcy.

It will increase. But on the other hand, the effective use of debt can greatly improve the income of enterprises, when enterprises

When operating well and making high profits, high debt will bring about the rapid growth of enterprises. Reasonable control and utilization of financial risks is an enterprise.

Another factor for the success of the industry.

ⅵ. Strengthening the internal audit supervision system

Internal audit supervision is an extremely important part of the whole financial control system, in order to ensure the overall purpose of the group company

To realize the target smoothly, the group company should establish an internal audit system and set up an audit department. So that on the one hand, the internal audit

The institutionalization, standardization and regularization of accounting work, on the other hand, is conducive to carrying out regular and irregular audit work, such as

Financial revenue and expenditure audit, economic responsibility audit, financial decision-making audit, infrastructure audit, etc., to ensure that the group company is timely.

Obtain accurate financial information and improve the scientific management decision.

Similarly, we also require that the financial management and control of the group company should be in line with the group strategy, especially the parent-subsidiary company.

Control framework, otherwise financial control will be like castles in the air, empty and gorgeous appearance, can not be made to the group

Substantial contribution. In this regard, multinational companies have set a good example for China enterprises.

1. How does the China government strengthen the supervision of multinational corporations?

The profit transfer and tax avoidance of multinational corporations in China really reflect their horizontal strategy and financial management.

Control ability, but we can't deny that there is still room for improvement in some systems of introducing foreign capital in China.

1.Gradually cancel the "super-national treatment" of multinational companies.

Since the reform and opening up, China's foreign investment policy has been "receiving" and "releasing", and the proportion of joint ventures and exports

Everyone has certain requirements. In terms of taxation, there are also preferential tax policies for foreign capital. The essence of utilizing foreign capital is to promote

The development of domestic economy, while the introduction of foreign capital is linked to the assessment criteria of local government officials, on the one hand, it can promote

On the other hand, too much foreign investment will have a greater impact on the local economy.

The 11th Five-Year Plan for Business Development, issued by the Ministry of Commerce, proposes to phase out the "super-nationals" of foreign investment.

Treatment ",so that domestic enterprises and foreign-funded enterprises compete on an equal footing at the same starting line, so that the world can see China's foreign.

Opening up is in line with international standards.

It is also an urgent task to rebuild the preferential tax policies in China's foreign-related tax law reasonably. Numerous offers.

The deletion and updating of policies will make it impossible for foreign-invested enterprises to use preferential policies for international tax avoidance.

2. Strengthen international anti-tax avoidance work

I standardize the transfer pricing tax system and establish an international market price information system.

In practice, we should do a good job in the following four aspects: first, set up a special machine to implement the transfer pricing tax system

Structure, formulate specific implementation plans and systems. Second, tax investigation and accounting adjustment should be carried out simultaneously to effectively protect the cooperation.

Chinese interests of foreign-funded enterprises. Third, strictly implement the accounting audit system of foreign-related enterprises by certified public accountants in China, so that

Part of the transfer pricing was adjusted in the audit stage. Fourthly, the tax authorities should establish a sound and systematic international market.

The collection system of market price data provides a basis for adjusting and confirming transfer pricing.

II. Improve the tax legislation and expand the tax authorities' anti-tax avoidance power.

Anti-tax avoidance clauses should be formulated separately in the tax law, and its main contents should include: defining the concept of affiliated enterprises, which are

International anti-tax avoidance provides legal basis; Improve the laws and regulations to prevent transfer pricing tax avoidance, and refer to the country when formulating laws and regulations.

The principle of normal transaction, the principle of shifting the burden of proof and the principle of tax compromise, etc., which are commonly used internationally, shall be treated as normal transaction for transnational pricing.

The principle is adjusted afterwards; It is clear that the tax authorities have the right to make adjustments when they have sufficient information and conclusive data.

Decision on consolidation and punishment; Formulate punishment rules for taxpayers who do not cooperate with tax authorities; Clear the relevant departments in the international

Anti-cooperation function in tax avoidance, and formulate punishment clauses for non-cooperation and violation of regulations of relevant departments; Modify and supplement as soon as possible

Close the applicable tax clauses of e-commerce, and make clear the time, time limit and tax payment of the tax obligation of online commerce.

Location, tax rate, tax information declaration and storage system, etc.

Iii. adapt to the new situation and take corresponding measures to prevent international tax avoidance in e-commerce.

First of all, we should establish a tax collection and management system that meets the requirements of e-commerce and strengthen the construction of the tax authorities' own network.

Realize the connection with banks, customs and online business users on the Internet as soon as possible, and realize real online supervision.

Control and inspection, and strengthen online cooperation with tax authorities in various countries. Second, the implementation of e-commerce tax registration system,

Taxpayers must go to the tax authorities for e-commerce tax registration after going through the online transaction procedures. sequence

Third, from the payment system to solve the problem of e-commerce tax collection and management, to prevent the loss of tax sources. Consider putting electrons

The payment system established and used by business as a means of checking, tracking and monitoring transaction behavior. Fourth, organize research.

Develop intelligent tax collection software to form an online automatic tax collection system, which can automatically identify the taxable transactions realized through the network.

For goods or services, determine the applicable taxes, tax items and tax rates, automatically calculate the tax amount, and automatically transfer the tax amount to the tax.

In the account designated by the agency. Fifth, we should strengthen international tax cooperation and improve international tax agreements.