跨国关联企业的转让定价问题现在已经成了国际税务专家们研究的热点,世界各国政府也对此采取了许多对策。从今年7月1日起,我国开始实施新的《外商投资企业和外国企业所得税法》。该法第十三条规定:“外商投资企业或者外国企业在中国境内设立的从事生产、经营的机构、场所与其关联企业之间的业务往来,应当按照独立企业之间的业务往来收取或者支付价款、费用。不按照独立企业之间的业务往来收取或者支付价款、费用,而减少其应税的所得额的,税务机关有权进行合理调整。”贯彻实施这一重要法 The transfer pricing of transnational affiliates has now become a hot spot for international tax experts, and many governments around the world have taken many measures against this. From July 1 this year, China began to implement the new “Foreign-Funded Enterprises and Foreign Enterprise Income Tax Law.” Article 13 of the Law stipulates: “Business transactions between foreign-invested enterprises or foreign-funded enterprises or establishments or establishments engaged in production or business operations in China and their affiliated enterprises shall be charged or paid in accordance with the business dealings between independent enterprises , The tax authorities shall have the right to make reasonable adjustments if they do not charge or pay the price and expenses in accordance with the business transactions between independent enterprises and reduce their taxable income. ”The implementation of this important law