转让定价一直以来都是各国税务当局反避税的重点和难点 ,而无形资产由于其独占性和专有性的特点 ,调整起来就更加困难。美国作为发达的开放型市场经济国家 ,经过几十年的实践和不断的修改 ,已建立起一套包括无形资产定义、调整方法的选择与运用以及事后调整制度在内的详尽的无 Transfer pricing has always been the focus and difficulty of tax authorities in all countries, and intangible assets are more difficult to adjust due to their uniqueness and exclusivity. As a developed and open market economy country, the United States has established a set of exhaustive and detailed rules including the definition of intangible assets, the selection and application of adjustment methods and the post-adjustment system after decades of practice and constant revision