跨国企业采用转让定价的内部交易,其内容多种多样,大体有商品购销、贷款往来、劳务提供、特许权及无形财产转让、固定资产代购租赁等方面。如果以大类区分,可分为商品交易和劳务交易两大类。两类中,劳务交易的内部定价情况更为复杂,计资往往界限不清,定价的规范程度更差。现将当前跨国企业内部提供劳务情况和转让定价办法等问题简要评述如下: 一、跨国企业内部提供劳务概况 The internal transactions adopted by multinational enterprises for transfer pricing are diversified in content, such as the purchase and sale of commodities, the loan transactions, the provision of labor services, the transfer of concessions and intangibles, and the leasing of fixed assets. If you distinguish between categories, can be divided into two major categories of commodity trading and labor transactions. In both categories, the internal pricing of labor transactions is more complicated, fund accounting often unclear, and pricing is even less standardized. The current briefing about the internal labor service performance and transfer pricing methods of multinational corporations is as follows: I. Overview of the internal labor service provided by multinational enterprises