为了有效防止跨国纳税人的国际逃税避税行为,有关国家可以从两个方面采取措施:一方面,通过颁布和修订国内立法,改变在某些问题上无法可依的状况,进一步完善税法体制,加强对跨国纳税人的税务监督管理;另一方面,国家可以通过与其它国家鉴订有关的税收协定,取得对方政府和税务机构的配合协助,以弥补国内立法上的不足和缺陷。在我国,核算合营企业应纳税所得额时,具有涉外意义的主要有以下几个方面:第一,合作外方所出资本的计价;第二,合营外方或其联属公司引进技术、购进原材料设备、举借资金及提供劳务等的计价;第三,合营企业产品通过其合营外方及其联属公司销售时的计价。对于合营企业购进、受让、租借资产的计 In order to effectively prevent international tax evasion and tax avoidance behavior of multinational taxpayers, the countries concerned can take measures from two aspects. On the one hand, through enacting and revising domestic legislation, changing the situation that is untenable on certain issues, further improving the tax law system and strengthening On the other hand, the state can obtain the cooperation and assistance from the counterpart government and taxation agencies through the taxation agreements with other countries in order to make up for the deficiencies and deficiencies in domestic legislation. In our country, when calculating the amount of taxable income of a joint venture, there are mainly the following aspects that are of foreign significance: first, the valuation of the capital contributed by the foreign partner of the joint venture; secondly, the technology import and purchase by the foreign joint venture or its affiliates Raw materials and equipment, borrowing of capital and provision of labor services, etc .; and thirdly, the valuation of joint ventures when they are sold through their joint ventures and their affiliated companies. For joint ventures purchase, transfer, lease of assets of the plan