| After WWII, with the surging up of economic globalization, international capital is expanding around the world rapidly, whilst multinational enterprises (MNEs) are achieving great development. At the same time, the internal trade among MNEs is taking a more and more outstanding role in international trade. As a result, transfer pricing in internal trade has become a main channel and strategy for MNEs to achieve global expansion. Since transfer pricing has a strong impact on the taxation of related investment countries, it will be of great value on researching in this area.As an important department of duty collection and supervision, customs will inevitably be affected by transfer pricing. In recent years, some research has already argued that transfer pricing has a close relationship with customs duty collection. Facing with a more severe and complicated commercial environment, China customs has to strengthen the supervision on customs price in light of transfer pricing among MNEs.This paper begins with the theory of transfer pricing, generally introduced the motive, impact and mode of transfer pricing among MNEs, by which strengthen the cognition of the conception of transfer pricing. Consequently, it compare and analyses the development course of transfer pricing of OECD and couple of countries, clarifies the principle and method on the supervision of transfer pricing of related international organizations and countries. On this basis, the paper analyses the fundamental principle in the supervision of transfer pricing and current status of legislation of customs in the world, and the latest research result of WCO in this area, from a perspective of valuation system of WTO and legislation on customs valuation of China and other countries, by which clarifies the weakness and challenge of China customs in the background of newly appeared commercial mode and consequent transfer pricing. Finally, the paper gives some suggestions on strengthen the supervision of transfer pricing of China customs, from the perspective of theory optimization, customs legislation, and specific operation on transfer pricing of customs. |