转让定价是指关联企业之间在销售货物、提供劳务等时制定的内部交易价格。跨国集团在经济一体化发展的过程中,采用关联企业之间的转让定价,来进行各种形式的逃税、避税,这已经成为各国税务机关普遍关注的问题。而转让定价税制则是针对转让定价行为在税收法律与实践方面作出的调整性规范,其目的在于维护税 Transfer pricing refers to the internal transaction prices established by the affiliated enterprises when selling goods, providing services, etc. In the process of economic integration, transnational corporations have adopted various forms of tax evasion and tax avoidance by adopting transfer pricing among affiliated enterprises, which has become a widespread concern of tax authorities in various countries. The transfer pricing tax system is the transfer of pricing behavior in the tax law and practice to make the regulatory norms, which aims to maintain the tax