2004年以前我国的反避税案件都是单边税收调整,普遍存在跨国重复征税的问题。从2005年开始,我国借鉴国际惯例,引入双边磋商机制,陆续签订了中日、中美、中韩双边预约定价,成功开展与跨国企业关联交易对方所在国税务当局的转让定价对应调整磋商,有效防范和消除了跨国重复征税,我国反避税工作进入新的历史时期。 Before 2004, all anti-avoidance cases in our country were unilateral tax adjustments, and the problem of cross-border taxation was common. Since 2005, our country has borrowed international conventions and introduced bilateral consultation mechanisms. China has successively signed bilateral pre-pricing agreements with China, the United States, and China and South Korea, and successfully negotiated the transfer pricing adjustment with the tax authorities of the countries where the transnational corporations are affiliated. Prevent and eliminate double taxation across borders, and our anti-tax avoidance work has entered a new historical period.