我国推行预约定价制的可行性、难题及对策

预约定价制是近些年来国际上兴起的用以解决跨国关联企业间转让定价税制问题的一项新型制度。世界各国为了有效地解决跨国关联企业转让定价这一国际难题都纷纷推行这一新型制度，我国近几年也开始引进这一新型制度，但实施有一定的难度，应尽快出台“预约定价操作规程，签订开展国际反避税的条约和协定，建立完善的价格信息系统，设置专业机构并配备专职的人员，逐步推行预约定价制。

On the Feasibility, Problems and Countermeasures about Promotion of APA in China

Advanced Price Agreement (APA) is a new system practiced for the cross-national enterprises among themselves to solve the problem about the transfer of price system of taxes, which is internationally used. The system has been introduced into China and put into practice. The paper argues that there are some difficulties for China to practice the system and the promotion of the system requires countermeasures to be taken such as setting up relevant regulations, signing relevant treaties and agreement for anti-tax-shunning internationally, establishing perfect price information system together with institutes with professional staff.