当前世界各国税制改革的趋势仍然是降低税率,扩大税基,加强征管。对关联企业转让定价税制的建立与完善,是加强税收征管的一项重要内容。但转让定价的税务处理政策性强,工作难度大,征纳双方经常出现争议。为了减少征纳双方对转让定价税务处理的争议,近年来有些国家着手试行“预约定价制”(advancedprincing agreement,APA),美国、日本实行预约定价制(preconfirmation system),态度尤为积极。目前虽然收效还不大,但它作为实施转让定价税制的一项新措施,不仅涉及到一国政府和其跨国纳税人之间的税收征纳关系,同时还涉及到国家政府和国家政府之间的税收分配关系,因而引起人们的关注。 At present, the trend of tax reform in all countries in the world is still to reduce the tax rate, expand the tax base and strengthen the collection and management. The establishment and improvement of the transfer pricing tax system for affiliated enterprises is an important part of strengthening tax collection and administration. However, the transfer pricing policy of tax treatment is strong, difficult to work, the two sides involved in the frequent controversy. In order to reduce the controversy over the tax treatment of transfer pricing by both parties, some countries have taken the pilot APS in recent years and the preconfirmation system has been implemented in the United States and Japan. The attitude is particularly positive. Although it has not achieved much success now, as a new measure to implement the transfer pricing tax system, it not only involves the tax collection and levying relations between a government and its multinational taxpayers, but also between the national government and the national government Of the tax distribution, which aroused people’s attention.