转让定价,已经成为现代跨境公司为达到国际避税目的所实施的重要措施。转让定价不仅有其固有的概念,亦存在特有的规制原则,本文阐述了转让定价的两大调整方法(传统价格法和比较利润法)和新发展的预约定价安排制度,并且比较三者在实际操作层面的优势与缺陷,进而在此基础上对其进行了简要的评析,提出具体适用的建议。 Transfer pricing has become an important measure taken by modern cross-border corporations to achieve the purpose of international tax avoidance. The transfer pricing not only has its inherent concept, but also has its own special regulation principle. This article elaborates two adjustment methods (traditional price method and comparative profit method) of transfer pricing and the newly developed reservation pricing arrangement system, and compares the three methods in practice The advantages and disadvantages of the operational level, and then on the basis of a brief analysis of its, put forward specific recommendations.