目前非居民企业股权转让是我国税务机关涉外税收征管中面临的难题之一。具体而言,选择何种方法进行转让定价调整存在争议。笔者从法律保留、证明责任以及资产评估角度对这一问题进行了探讨。 At present, the non-resident enterprise equity transfer is one of the problems that the tax authorities in our country face in the tax collection and administration. In particular, there is debate over which method to choose to make the transfer pricing adjustment. The author discusses the issue from the angle of legal reservation, burden of proof and asset appraisal.