一、避免关联企业转移定价双重征税的现有机制及评析 目前避免关联企业转移定价双重征税的机制可大致分为两类,即事前预防机制和事后调整机制。 事前预防机制主要是目前在一些国家之间实行的“双边预约定价制”。它是指跨国关联企业事先取得交易所涉国的税务机关对关联企业转移定价或成本分摊协议价格的认可,并遵照各国税务机关之间就内部。交易价格、付款方式等达成的协议进行交易。对此,各国税务机关事后不再对转移定价进行税务审查与调整。例如,1992年美国税务总署与澳大利亚税务局对苹果计算机公司销售给其在澳大利亚子公司产品,再由后者转售的内部交易行为达成预约定价协议,协议有效期为4年,并且实际价格可在规定价格的3％以内浮动,以适应不断变化的形 First, to avoid the existing mechanism of transfer tax double-taxation of affiliates and analysis of the current mechanism to avoid double taxation of transfer pricing affiliates can be broadly divided into two categories, namely, the precautionary mechanism and ex post adjustment mechanism. The precautionary mechanism is mainly the “bilateral pre-set pricing system” that is currently in place among some countries. It refers to the multinational affiliates prior access to the tax authorities involved in the transaction of the transfer pricing of affiliates or cost-sharing agreement price recognition, and in accordance with the internal tax authorities within the state. Transaction price, payment method and other agreements reached by the transaction. In this regard, the tax authorities in various countries no longer post tax review and adjustment of transfer pricing. For example, the U.S. Inland Revenue Department and the Australian Revenue Agency reached an agreed-upon pricing agreement for the sale of Apple Computer’s products to its Australian subsidiary in 1992, which were then resold by the latter. The agreement is valid for 4 years and the actual price may be Float within 3% of the stipulated price to accommodate the changing shape