目前,世界上已有70多个国家实行了转移定价税制。国际上通行的对转移定价的监控主要包括以下几个方面:(1)关联企业的认定。判明有关国内外企业是否存在着关联关系是各国在分析企业问是否存在通过转移定价进行避税的问题时首先必须解决的问题。日本转移定价法规认定关联企业有两个依据:其一,以股权占有关系为依据,握有企业股本50%及以上者即为关联企业; At present, more than 70 countries in the world have implemented a transfer pricing tax system. The internationally accepted monitoring of transfer pricing mainly includes the following aspects: (1) Recognition of affiliated companies. It has become clear that whether domestic or foreign companies have a affiliated relationship is the first question that countries must address in their analysis of whether a business asks for tax avoidance through transfer pricing. Japan’s transfer pricing laws and regulations recognize that there are two basis for affiliated companies: First, based on the equity ownership relationship, those holding 50% or more of the company’s share capital are affiliated companies;