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多年来,国际组织和各国政府针对转让订价问题所作出的努力和经验积累,已经初步取得一种共识:即联属企业的内部转让订价,应按独立核算企业之间的正常交易价格来加以调整:在缺乏可比正常交易价格下的某些推算方法,也基本上被各方所认可。但是,在跨国法人集团内部贸易额迅速扩大,以至达到占整个世界贸易额40％左右比重的今天,怎样做到使正常交易价格这一原则,能够更好地同跨国业务经营中错综复杂的客观实际相结合,如实地兼顾有关各方的合理利益,从而得到有效地贯彻执行,却仍然是一个颇感棘手的难题。矛盾
Over the years, the efforts and accumulated experience of many international organizations and governments on the issue of transfer pricing have tentatively reached a consensus that the internal transfer pricing of affiliates should be based on the normal transaction prices between independent accounting firms Adjustment: Some estimates in the absence of comparable normal transaction prices are also largely recognized by all parties. However, as the internal trade volume of multinational corporations rapidly expands to about 40% of the total world trade, how to make the principle of normal trading price better able to better meet the complicated objective reality in multinational business operations? However, it is still a very difficult problem that the combination of faithful consideration of the legitimate interests of all parties concerned and the effective implementation of the law should be implemented. contradiction