由于各国在税收制度上存在着差异，一个跨国关联企业集团必然从总体利益出发，对它的跨国收入与费用进行全盘考虑，通过转让定价把收入尽可能等地分配到低税率国的关联企业和把费用尽可能多地分配到高税率国的关联企业，使其跨国收入和费用在最有利的地点获得和发生，从而逃避? Because of differences in tax systems among different countries, a transnational affiliate group must take overall interests into account and consider its transnational income and expenses in a holistic manner. It should allocate its income as much as possible to its affiliates in low-tax countries through transfer pricing and As far as possible to allocate the cost of affiliates in high-tax countries, cross-border income and costs of its acquisition and occurrence in the most favorable locations, so as to evade?