目次一、根源追溯:缘起制衡税权与纳税人权利二、本体认知:基于税权谦抑行使的征纳合作三、理念提炼:均衡分配税收利益的意蕴四、规范配置:预约定价的实体与程序规则五、责任归咎:预约定价安排执行争议的解决六、结论预约定价安排是转让定价税制的创新:这一制度虽然并不适用于所有纳税人,其所蕴涵的合作、协调的理念却足以使其成为现代税法的重要发展成果。预约定价安排是税法精心设计的可供 First, the source of traceability: the origin of the tax balance between tax rights and taxpayers rights Second, the ontology of cognition: based on the tax humble implementation of the levy and cooperation Third, the concept of refining: the balanced distribution of the implications of tax benefits Fourth, the standard configuration: pre-pricing entities And procedural rules 5, attribution of responsibility: reservation pricing arrangements to resolve the implementation of the dispute VI Conclusion Appointment pricing arrangement is the transfer pricing tax system innovation: Although this system does not apply to all taxpayers, the implication of cooperation and coordination of the concept is Enough to make it an important development of modern tax law. Appointment pricing arrangements are well-designed tax laws available