欧盟转移定价之同期资料规则有两大特色:第一,形成了欧盟内部统一的关联企业转移定价同期资料行为守则;第二,制定了中小型企业特别保护条款。其最终目的是降低欧盟境内企业的遵从成本和各成员国税务当局的行政管理成本。鉴于同期资料规则已经是各国转移定价税制的必备条款,而中小型企业是各国经济和社会生活中的重要组成部分,欧盟的同期资料规则具有相当大的时代意义。本文首先分析并梳理了欧盟同期资料规则的立法背景和主要成果,然后解读了欧盟同期资料规则的基本内容,接下来对其进行评析,最后提出对我国的借鉴。 There are two main characteristics of the EU data transfer pricing rules over the same period: first, a uniform code of conduct for the transfer pricing of affiliated enterprises in the EU has been formed; secondly, special protection provisions for small and medium-sized enterprises have been formulated. Its ultimate goal is to reduce the compliance costs of enterprises within the European Union and the administrative costs of tax authorities in member states. In view of the fact that the data regulations of the same period are already the necessary provisions for the transfer pricing tax system in various countries, the small and medium-sized enterprises are an important part of the economic and social life of all countries. The EU data synchronization rules of the same period have a great significance in the present era. This article first analyzes and combs the legislative background and major achievements of the EU data rules of the same period, then interprets the basic content of the data regulations of the EU over the same period, and then comments on it, finally proposes its reference to our country.