(1) Commodity transactions between related enterprises adopt the strategy of lowering pricing, so that the turnover tax payable by the enterprise is transferred into profits to avoid tax. For example, an enterprise that is subject to a basic tax rate of 17% sells self-made semi-finished products at a low price to an associated enterprise that is subject to a low tax rate of 13% in order to reduce the VAT burden. Although it reduces the company's sales, it makes the associated enterprise more profitable. Enterprises can also share more profits from joint ventures, thus achieving the purpose of reducing tax burdens.
(2) Commodity transactions between related enterprises adopt the strategy of raising prices to transfer income and avoid taxes. Some companies that implement a high rate of value-added tax deliberately raise the purchase price when purchasing products from their affiliated enterprises with a low tax burden, and transfer profits to the affiliated enterprises. This can not only increase the value-added tax deduction of the enterprise, reduce the value-added tax burden, but also reduce the income tax burden. Then, get an extra portion of the extra corporate profits retained by affiliated companies with low tax burdens.
(3) Affiliated enterprises transfer profits by increasing or decreasing loan interest to achieve the purpose of tax avoidance. As a form of investment between related enterprises, loans have greater flexibility than equity participation. Subsidiaries in affiliated enterprises repay the parent company's investment returns in the form of dividends, which cannot be deducted as an expense when paying taxes, while the interest paid can be deducted as an expense before income tax is levied. Therefore, profits can be transferred between related enterprises through transfer pricing in loans. In order to increase the profits of the other party, an affiliated enterprise can provide loans, charge less or no interest, and reduce the production expenses of the enterprise to achieve the purpose of profit; on the contrary, in order to cause the other affiliated enterprise to suffer losses or make small profits, it can achieve the purpose of reducing taxes. The purpose is to charge loan interest at a higher interest rate and increase the cost of its products. There are also some companies with relatively abundant funds or easy sources of loans. Due to their relatively heavy tax burden, they often use free loans or payments to their affiliated companies. In this way, all the interest paid on this part of the funds is paid by the company that provides the funds. The burden on enterprises increases costs and reduces income tax burdens.
(4) The provision of labor services between related enterprises adopts the method of not calculating remuneration or collecting remuneration in an irregular manner to avoid tax by transferring income. For example, when some enterprises provide sales, management, administrative or other services to their affiliated enterprises, they do not calculate and collect remuneration according to conventional methods, and adopt the strategy of overcharging, undercharging or not collecting to avoid taxes by transferring income to each other, that is, when it is beneficial to which party Whichever side you transfer to. What is particularly prominent at present is that the laid-off surplus personnel of some state-owned enterprises have set up factories to run the economy or the tertiary industry, but their wages are still paid by the original enterprises, which reduces the income tax burden of the original enterprises and increases the profits of the new enterprises.
(5) Affiliated enterprises transfer profits through the transfer or use of tangible or intangible assets at unconventional prices to avoid taxes. For example, if some enterprises sell or dispose of idle fixed assets to affiliated enterprises at unconventionally low prices, part of the losses will be borne by the enterprise's costs, reducing the income tax burden. Another example is that some companies provide their own production formulas, process technologies, trademarks and franchises to affiliated companies free of charge or at low prices. The remuneration is not calculated through technology transfer income, but benefits from the other party's corporate profits. This not only achieves the purpose of reducing the tax burden, but also solves corporate welfare and other needs.
(6) Transfer pricing through fixed asset leasing affects profits. For example, in financial leasing, the lessee pays a lease fee during the lease period. After the lease expires, the property rights of the equipment are transferred to the lessee. The lease fee generally includes the equipment price, handling fees, payment interest, etc. When tangible assets are leased between related companies, the rental rate directly affects the profit level of the related companies. Affiliated companies transfer fixed assets through the leasing of fixed assets and can transfer profits by charging high or low rents.
(7) Avoid taxes through fee transfer pricing. For example, by extracting management fees to affect corporate costs; by artificially creating bad debts and loss compensation to increase corporate expenses; by using sales commissions and rebates to affect product sales revenue, using controlled transportation systems to charge higher Or lower transportation, loading and unloading, and insurance costs can affect product sales costs to achieve the purpose of transferring profits and avoiding taxes.
(8) Serial pricing method.
The so-called "serial pricing" method means that the associated enterprises involved in transfer pricing are not simply between a domestic company and an overseas company, but extend to two or several overseas affiliated companies. After many transactions, the latter finally The tax avoidance results caused by transfer pricing in each link are distributed to various intermediate links, thus concealing the essence of transfer pricing. Since my country officially implemented the transfer pricing tax system in 1991, it has basically adopted the cost-plus method or the verified profit method, which is easier to operate. That is, it uses comparative profits to disprove the unreasonable transfer pricing and uses reasonable profits to reflect the principle of normal transactions. , the scope of adjustment is also concentrated on companies that have direct business dealings with overseas affiliated companies, that is, so-called companies with "two ends outside" or "one head outside". These characteristics make serial pricing tax avoidance more obvious in its hidden advantages.