Research on Transfer Pricing and International Tax Avoidance of Chinese Enterprises: An Empirical Test on Commodity Export Trade

Abstract

Multinational enterprises that shift profits and thus conduct international tax avoidance through transfer pricing mode have aroused widespread concern in developed countries. In recent years, China continues to expand foreign direct investment scales, but accompanying phenomenon of international tax avoidance has not aroused enough attention. According to the model established by Bernard et al. (2006), and considering the specific provisions of Chinese anti avoidance system, this paper puts export amount and tax rate difference into the decision equation of price differences, so that it can theoretically explain the existence and heterogeneity of international tax avoidance in Chinese foreign investment enterprises through transfer pricing and anti avoidance effect. Then it uses Chinese customs export data from 2000 to 2006 and DDD method to conduct an empirical test. It comes to the results as follows: firstly, Chinese foreign investment enterprises use transfer pricing to do tax avoidance in the export trade, and the greater tax differences between destination countries and China lead to deeper degree of differences of transferred prices deviating from prices of fair trade; secondly, the level of tax avoidance varies with enterprise ownership and industries to some extent, namely tax avoidance of domestic enterprises and capital intensive industries are more serious than foreign enterprises and labor intensive industries respectively; thirdly, tax treaty plays a very limited role in anti tax avoidance focusing on transfer pricing. This paper provides a way of thinking to help us to understand current going-out behavior of Chinese enterprises from a perspective of tax avoidance motivation and also a reference for current Chinese anti tax avoidance system.