赴荷兰考察,对当今世界转让定价税制的宏观分析与实务处理有些新认识,有必要联系我国实际,提出新的思索和探讨。一、国际现状转让定价税制基本上是在经济发达国家中建立起来,发展中国家建立此制的不过是少数。就经济发达国家来说,转让定价税制目前依然处于初始阶段。起步比较早,立法比较健全,操作办法比较具体,而且已经取得一定成效的只有美国。从1973年至今,美国共调整转让定价1572起,调增应税所得大致几十亿美元。其他西方国家,有的只是规定一些基本法规,如德国、英国等。有的连基本法规也 To visit the Netherlands, the world today, the transfer pricing tax macro-analysis and practical handling of some new understanding, it is necessary to contact our reality, put forward new thinking and discussion. First, the current status of the international transfer pricing tax system is basically established in economically developed countries, developing countries to establish this system is only a minority. For economically developed countries, the transfer pricing tax system is still in its infancy. The start was earlier, the legislation was relatively sound, and the methods of operation were more specific. And only the United States has achieved some success. Since 1973, the United States has adjusted a total of 1,572 transfer pricing and raised its taxable income by almost several billion U.S. dollars. In other western countries, some only stipulate some basic laws and regulations, such as Germany and the United Kingdom. Some even basic laws and regulations