Chuyển giá thông tin qua thủ thuật tách lợi nhuận của các công ty đa quốc gia tại Việt Nam

Abstract

In recent years, the fight against transfer pricing in Vietnam bas achieved certain success. However, in the contexxt of international economic integration, deeper and wider, the transfer pricing for the purpose of tax avoidance was fairly popular form to take advantage of the difference in the rates of corporate income tax between counties to implement the transfer of profit ( or loss transfer) reciprocal. This article will focus on transfer pricing analysis through profit split method based on the right to dispose of the market price of multinational companies in the business transactions between a company and its subssidiary. Recommendations to limit the transfer pricing are also included in this paper.