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一、预约定价制的定义评述 1.狭义说。 狭义说的预约定价协议,特指预约定价协议(Advanced Pricing Agreements),即跨国纳税人与一国或多国税务主管机关之间就其与关联企业间受控交易将要涉及的转让定价方法、利润水平等问题所达成的协议。国内有学者采用此狭义说,将预约定价定义为:纳税人事先将其和境外关联企业之间的内部交易与财务收支往来所涉
First, the definition of the reservation pricing system comments 1. Narrowly said. In the narrow sense, the APA refers to Advanced Pricing Agreements, the transfer pricing method that the multinational taxpayer and the tax authority of one or more countries consider to be involved in the controlled transaction with the affiliated enterprise, the profit level And other issues reached by the agreement. Some domestic scholars adopt this narrow sense to say that the pre-pricing pricing is defined as that the taxpayer has previously involved the internal transactions and the financial receipts and disbursements between it and its overseas affiliates