转让定价广泛存在于跨国公司的日常运营过程中,是跨国公司经常采用的一种避税手段。近年来,国家税务总局发布了一系列关于特别纳税调整的法律法规文件,对转让定价的监管更加严格。但是在转让定价的承接和实施中也面临很多问题与挑战,难点主要是对于转让定价的理解和应用上。对此,税务师事务所应当认真研究,来应对新的变化和需求。独立交易原则在转让定价税制中占据着核心的地位。新《企业所得税法》也将关联方之间的业务往来是否符合独立交易原则作为税务机关进行税收调整的标 Transfer pricing is widely existed in the daily operation of multinational corporations and is a tax avoidance method often adopted by multinational corporations. In recent years, the State Administration of Taxation has promulgated a series of laws and regulations on special tax adjustments and has tightened its supervision of transfer pricing. However, it also faces many problems and challenges in the transfer and implementation of transfer pricing. The difficulties are mainly the understanding and application of transfer pricing. In this regard, tax office should seriously study to meet the new changes and needs. The principle of independent transaction occupies the core position in the transfer pricing tax system. The new “Enterprise Income Tax Law” also correlates whether the business transactions between related parties conform to the principle of independent transaction as the tax authority’s tax adjustment standard