Research On International Related Enterprises Transfer Pricing

International related enterprises can take advantage of varied means such as different tax rates and tax heaven, to conduct transfer pricing. To tax authority, both the "arm's length principle" and "the profit principle" are difficult to operate to solve this problem. So the advanced pricing agreement came into being in 1990's. And these issues, such as bilateral agreement, negotiation, exchange of information, dispute-settling mechanism, and so on, will be the emphases of international fiscal law research later.In general, our nation has lower tax rates than most nations. But there still are many foreign investment enterprises shifting their profits. Why? This paper makes an attempt to discuss on and research into some issues about international related enterprises transfer pricing, with a hope to make valuable contributions to our nation's transfer pricing research and adjustment.