跨国企业的转让定价问题是国际公认的最复杂的国际税务问题之一,也是各国税务机关的反避税工作重点。当一个国家的税务机关对跨国企业的转让定价进行调查调整时,会引起对该企业集团的重复征税。如果转让定价调整的关联交易双方所在国家之间签署了避免双重征税的税收协定,企业就可以通过向主管税务当局申请通过相互协商程序解决国际重复征税问题。除了利用相互协商程序解决针对调查调整而引起的国际重复征税外~①,本文介绍另外一种在国际重复征 The issue of transfer pricing of multinational corporations is one of the most internationally recognized international tax issues and also the focus of anti-tax avoidance efforts of tax authorities in various countries. When the tax authorities of a country investigate and adjust the transfer pricing of transnational enterprises, it will cause double taxation on the group of enterprises. If a tax agreement to avoid double taxation is signed between the countries where the parties to the related-party transaction are subject to the transfer pricing adjustment, the enterprise can apply to the competent tax authorities to settle the issue of international double taxation through the process of mutual consultation. In addition to the use of mutual agreement to solve the investigation of adjustment caused by the international double taxation ~, this article describes another in the international repeat sign