转移定价是随着跨国公司税收的国际分配问题的产生而出现的。随着世界经济的不断发展,特别是企业集团的规模不断增大、数量不断增多,转移定价已不再是一个专属于国际税收的分配问题。由于在关联企业之间更容易发生转移定价,而且定价普遍围绕公允市价以不同幅度上下波动,较大影响了参与交易各方的经营状况,从而使转移定价披露机制问题摆在了一个更加重要的地位。 Transfer pricing occurs with the issue of the international distribution of multinational tax revenue. With the continuous development of the world economy, especially with the increasing size and number of enterprise groups, the transfer pricing is no longer a distribution problem that is exclusively for international taxation. As transfer pricing is more likely to occur among affiliates, and pricing generally fluctuates around the fair market at different rates, which greatly affects the operating conditions of all parties involved in the transaction, the issue of transfer pricing disclosure mechanism becomes more and more important status.