当前,转让定价税制已成为各国税务当局和跨国公司最为关注的国际税收问题,通过转让定价税制实施的反避税管理是跨国税源监控和维护国家税收权益的重要手段。转让定价税制并非一种专门税制,而是完善的税收体系中特殊的组成部分,是政府用来对跨国公司转让定价实施政策目标控制和管理的方法和措施。怎样正确进行企业所得税转让定价调整,是摆在税务师面前的一道难题,税务师要特别关注。税务部门对跨国公司进行转让定价调查、调整, At present, the transfer pricing tax system has become the most important international tax issue for the tax authorities and multinational corporations in all countries. The anti-tax avoidance management implemented through the transfer pricing tax system is an important means to monitor and safeguard the tax rights and interests of the state. The transfer pricing tax system is not a special tax system, but a special part of a sound tax system. It is a method and measure used by the government to control and manage the policy objectives of the transfer pricing of transnational corporations. How to properly carry out the transfer pricing adjustment of enterprise income tax is a difficult problem before the tax accountants, and tax specialists should pay special attention. Tax authorities on the transnational corporations transfer pricing survey, adjustment,