青山遮不住:APA扑面而来APA就是预约定价安排。随着经济全球化的发展,跨国公司的资金、技术、人才和信息等资源在全球范围内流动,其在全球范围的利润分配也越来越受到各国税务当局的关注,并引发各国税务当局对其转让定价的税务调整。由此,跨国纳税人不可避免地面临着被重复征税和纳税调整的不确定性。为此我国企业所得税法规定,企业可以向税务机关 Aoyama can not hide: APA blowing APA is booking an arrangement. With the development of economic globalization, the resources, such as capital, technology, human resources and information of transnational corporations, have been flowing around the world. Their profit distribution around the world has also drawn more and more attention from the tax authorities in various countries, and has caused the tax authorities in various countries Tax adjustment of its transfer pricing. As a result, multinational taxpayers inevitably face the uncertainty of double taxation and tax adjustment. To this end China’s Enterprise Income Tax Law provides that enterprises can tax authorities