内容提要：: in recent years, with the increasing power of developing economy, more and more attention is paid to the tax treatment of location advantages. this paper will discuss the impact of location advantages on the transfer pricing of multinationals, first examining the concept of location advantages and the transfer pricing aspects related thereto. specific guidance from the oecd and united nations on location advantages will also be considered, followed by a discussion of two international tax cases. finally, the current practice on location advantages and transfer pricing in the netherlands and in china, as examples, will be examined.