日立苏州转让定价税务风险防控的案例研究
发布时间：2018-09-13 14:12
【摘要】：资源和人力成本优势让我国成为外资企业制造业聚集地，我国转让定价税制日益完善和规范，税务机关反避税操作流程日益高效严格，使得这些承担单一制造功能的企业在我国面临着越来越严重的转让定价税务风险。 日立苏州属于计算机硬件制造业、被日立中国和日本日立株式会社控股、只进行单一的生产制造、产成品都售回日本，由母公司负责销售，在行业属性、股权结构、功能定位和交易模式上与单一功能风险企业十分契合。作为制造业单一功能风险企业的典型代表，日立苏州的处境和面临的转让定价税务风险以及其应对策略均具有典型性和代表性，本文以日立苏州为案例，对其转让定价风险防控策略进行分析。日立苏州服从企业集团整体定价策略造成了企业自身的转让定价风险，日立苏州最大的风险点在于运用成本加成法定价时没有比照同业利润率，将成本加成率定得过低。在准备同期资料过程中会牵涉转让定价方法的分析，根据税法规定和企业自身特殊性选择最恰当的定价方法，将定价理由在同期资料中详细阐述，结合企业只承担生产性单一功能的实际情况和企业面临的人工成本、原材料成本上涨等具体原因对利润率偏低进行解释说明，力求取得税务机关的认可，同时尽可能申请预约定价。 在案例分析的基础上，得出企业防控转让定价税务风险的管理策略与操作要领。第一，认清企业所面临的税务法律环境和税务监管环境，不能触碰法律红线，提交资料要符合当地税务机关关注重点。第二，建立以同期资料为依托的转让定价税务风险识别和评估机制，利用同期资料准备对企业涉税风险进行自查，识别风险并积极应对。第三，同期资料准备要从企业功能风险与利润匹配性、转让定价方法选取的合理性、可比性分析的有效性三个方面进行重点把控。第四，权衡利弊根据企业自身情况尽早申请预约定价安排。
[Abstract]:The advantages of resources and manpower cost have made our country a manufacturing gathering place for foreign-funded enterprises. Our transfer pricing tax system has become increasingly perfect and standardized, and the tax authorities' anti-tax avoidance operation process has become increasingly efficient and strict. These enterprises with single manufacturing function are facing more and more serious tax risk of transfer pricing in China. Hitachi Suzhou, which belongs to the computer hardware manufacturing industry, is controlled by Hitachi China and Japan's Hitachi Co., Ltd., which only carries out a single manufacturing process. The finished products are sold back to Japan, and the parent company is responsible for sales, industry attributes, and equity structure. Functional positioning and trading model with a single function of risk enterprises very suitable. As a typical representative of single-function venture enterprise in manufacturing industry, the situation of Hitachi Suzhou, the tax risk of transfer pricing and its countermeasures are typical and representative. This paper takes Hitachi Suzhou as a case study. This paper analyzes the risk prevention and control strategy of transfer pricing. The whole pricing strategy of Hitachi Suzhou has caused the transfer pricing risk of the enterprise itself. The biggest risk point of Hitachi Suzhou is that the cost addition rate is too low when the cost addition method is not compared with the profit rate of the same industry. The analysis of transfer pricing methods will be involved in the preparation of simultaneous data. According to the provisions of the tax law and the particularity of the enterprise itself, the most appropriate pricing method will be selected, and the pricing reasons will be elaborated in detail in the data of the same period. According to the actual situation that the enterprise only undertakes the single function of production and the labor cost and the rising cost of raw materials, the paper explains the low profit margin and tries to obtain the approval of the tax authorities. At the same time, apply for the reservation price as much as possible. On the basis of case analysis, the management strategy and operational essentials of tax risk of transfer pricing are obtained. First, understand clearly the tax legal environment and tax regulatory environment faced by enterprises, can not touch the red line of the law, the submission of information should be in line with the focus of local tax authorities. Second, establish the transfer pricing tax risk identification and evaluation mechanism based on the same period information, and use the same period information to prepare the enterprise tax risk self-inspection, identify the risk and actively deal with it. Thirdly, the data preparation of the same period should focus on three aspects: the matching of enterprise function risk and profit, the rationality of the selection of transfer pricing method, and the effectiveness of comparability analysis. Fourth, weigh the pros and cons according to the enterprise's own situation as early as possible to apply for pricing arrangements.
【学位授予单位】：湖南大学
【学位级别】：硕士
【学位授予年份】：2014
【分类号】：F416.671;F812.42
[Abstract]:The advantages of resources and manpower cost have made our country a manufacturing gathering place for foreign-funded enterprises. Our transfer pricing tax system has become increasingly perfect and standardized, and the tax authorities' anti-tax avoidance operation process has become increasingly efficient and strict. These enterprises with single manufacturing function are facing more and more serious tax risk of transfer pricing in China. Hitachi Suzhou, which belongs to the computer hardware manufacturing industry, is controlled by Hitachi China and Japan's Hitachi Co., Ltd., which only carries out a single manufacturing process. The finished products are sold back to Japan, and the parent company is responsible for sales, industry attributes, and equity structure. Functional positioning and trading model with a single function of risk enterprises very suitable. As a typical representative of single-function venture enterprise in manufacturing industry, the situation of Hitachi Suzhou, the tax risk of transfer pricing and its countermeasures are typical and representative. This paper takes Hitachi Suzhou as a case study. This paper analyzes the risk prevention and control strategy of transfer pricing. The whole pricing strategy of Hitachi Suzhou has caused the transfer pricing risk of the enterprise itself. The biggest risk point of Hitachi Suzhou is that the cost addition rate is too low when the cost addition method is not compared with the profit rate of the same industry. The analysis of transfer pricing methods will be involved in the preparation of simultaneous data. According to the provisions of the tax law and the particularity of the enterprise itself, the most appropriate pricing method will be selected, and the pricing reasons will be elaborated in detail in the data of the same period. According to the actual situation that the enterprise only undertakes the single function of production and the labor cost and the rising cost of raw materials, the paper explains the low profit margin and tries to obtain the approval of the tax authorities. At the same time, apply for the reservation price as much as possible. On the basis of case analysis, the management strategy and operational essentials of tax risk of transfer pricing are obtained. First, understand clearly the tax legal environment and tax regulatory environment faced by enterprises, can not touch the red line of the law, the submission of information should be in line with the focus of local tax authorities. Second, establish the transfer pricing tax risk identification and evaluation mechanism based on the same period information, and use the same period information to prepare the enterprise tax risk self-inspection, identify the risk and actively deal with it. Thirdly, the data preparation of the same period should focus on three aspects: the matching of enterprise function risk and profit, the rationality of the selection of transfer pricing method, and the effectiveness of comparability analysis. Fourth, weigh the pros and cons according to the enterprise's own situation as early as possible to apply for pricing arrangements.
【学位授予单位】：湖南大学
【学位级别】：硕士
【学位授予年份】：2014
【分类号】：F416.671;F812.42
【参考文献】
相关期刊论文 前10条
1 曹建新;詹长杰;;论税务风险管理与公司治理[J];财会月刊;2010年16期
2 琚敬;杨亚东;;《特别纳税调整实施办法(试行)》中预约定价规定的不足及完善[J];法制与经济(中旬刊);2010年05期
3 王s，
本文编号：2241399
本文链接：https://www.wllwen.com/jingjilunwen/gongyejingjilunwen/2241399.html
