一、连续亏损的背后改革开放以来,外商投资企业在我国的经济特区获得了迅速发展。总的来说,外资企业的发展是健康的、有益的,但在其发展中也存在许多问题,其中最令人头痛的莫过于外资企业的连续亏损。我们在考察中发现,连续亏损问题与外商利用各种形式的转让定价有着直接的关系。下面从合资企业和独资企业两方面入手,对经济特区面临的转让定价问题作一简单的揭示。跨国公司以合资经营形式建立的附属公司,必然会涉及到东道国的当地合作者。由于有些国家对合资企业中外方的控股比例有明确的限制,如规定最高不超过50%,这样对外方控股 1. Behind the continuous losses Since the reform and opening up, foreign-invested enterprises have achieved rapid development in China’s special economic zones. In general, the development of foreign-funded enterprises is healthy and beneficial, but there are also many problems in its development. The most troubling factor is the continuous losses of foreign-funded enterprises. During our investigation, we found that the issue of continuous loss has a direct relationship with foreign investors using various forms of transfer pricing. In the following, starting from joint ventures and sole proprietorships, a simple disclosure of the issue of transfer pricing faced by the special economic zones will be made. A subsidiary established by a multinational company in the form of a joint venture will inevitably involve local partners in the host country. As some countries have clear restrictions on the controlling shareholdings of Chinese and foreign companies in joint ventures, if the maximum is not more than 50%, such foreign holdings