跨国企业A公司的产品销售以关联交易为主,涉嫌自制标准成本进行虚假核算,关联借款超标侵蚀利润,税负率低,账务处理违规,长亏不倒仍扩大规模,通过关联交易转让定价避税,被立案反避税调查。历经一年多艰辛的谈判博弈,调查人员创新特别纳税调整方法,借助数学统计工具—线性回归模型,征纳双方就企业营业费用影响毛利率的难题达成共识,A公司接受调整方案。 The sales of product of multinational corporation A Company are mainly related party transactions. The standard cost of self-made is false accounting, the related borrowing exceeds the standard and erodes the profit, the tax rate is low, the accounting treatment is irregular, and the long-term deficit is still enlarged. Tax evasion, filing anti-tax avoidance investigation. After more than a year of difficult negotiation game, investigators innovated the special tax adjustment method, and with the help of the mathematical statistical tool - linear regression model, the two parties reached a consensus on the problem that the operating expenses of the enterprises affect the gross profit margin. Company A accepted the adjustment plan.