税收优化的供应链管理及转移定价.ppt

Tax-efficient Supply Chain Management Transfer Pricing Page * Tax-efficient Supply Chain Management Transfer Pricing Contents TESCM Background The Concept Overall Structure Design Entity Characterization Alternative Structures Location of Principal Co Benefits Key Tax Issues Recent Developments OECD Discussion Draft on Transfer Pricing Aspects of Business Restructuring Tax-efficient Supply Chain Management Background Discernible change in multinational business models “Local” business models giving way to regional and global supply chain structures Growing centralization of multinational decisions at a regional or international level Traditional tax structures impacted by the geographical blur in cross-border business models Background MNEs have grown across the globe with some patterns: Manufacturing located near raw material sources, customer markets Sales organizations dispersed Management in the country of “origin” May be doing business in a number of “High Tax Jurisdictions” (“HTJs”) Tax base would correspond with the economic activity in the country Effective tax rate – cumulative weighted average tax rate Traditional Supply Chain Model Buys materials Manufacturer Inventory risks Warranty risk Intangibles Capital investment Buys finished goods Distributor Inventory risk Warranty risk Intangibles Pricing risk Volume risk Credit risk Sells finished goods Customer Each entity in the supply chain assumes risks associated with respective functions Profit arising from the economic activities in the respective jurisdictions attributed to the jurisdiction Issues with Traditional Supply Chain Models Customer relations Fragmented by country Multiple points of contact In some cases, “competition with ourselves” Duplicative functions across countries Increases costs Manufacturing managed by country Short production lines Possible results Higher worldwide effective tax rate Lower profitability What is TESCM? Supply Chain Management (“SCM”) is defined as the manage