Copying and distributing are prohibited without permission of the publisher

China: How China has developed its transfer pricing rules

23 March 2011

Cheng Chi, Irene Yan, Leonard Zhang and Ho-Yin Leung of KPMG describe a transfer pricing system in China that is getting more sophisticated and international

Circular Guoshuifa [2009] No 2, "The Implementation Measures of Special Taxation Adjustments (Provisional)" was enforced for the second consecutive year in China in 2010. As background, China has revamped its transfer pricing regime since 2008, after the promulgation of its new corporate income tax law (CIT Law). Changes and improvements to the regime were introduced in circular 2 by the State Administration of Taxation (SAT) in January 2009. This circular together with the new CIT Law became retroactively effective on January 1 2008. Transfer pricing regulations in China are considered to be comprehensive and one of the most extensive and demanding in the world, particularly in relation to contemporaneous documentation requirements.

In 2010, a number of important transfer pricing developments took place in China.

SAT's recent development The SAT has been strengthening its workforce for transfer pricing related cases. In early 2010, about 100 transfer pricing specialists were employed across the...



This article is locked content, available to current subscribers or triallists.

  • Current subscribers or trialists - Please log in to view this article in full.
  • New users - Please take a free 7 day trial.
  • Expired subscribers or trialists - Please subscribe to gain immediate full access.

If you think you've received this message in error, please contact your account manager, Nick Burroughs:
Email: nburroughs@euromoneyplc.com, Tel: +44 (0)207 779 8379

Subscribe now

Subscribe today to gain full access to International Tax Review.

Subscribe

Free trial

Take a free trial now and gain 7 days of full access to International Tax Review.

Free trial




Latest Issue

View Issue

July / August 2014

One lap to go: BEPS at half time

As those involved in the OECD's base erosion and profit shifting (BEPS) project reach for the halftime oranges and energy drinks, our special BEPS feature looks at the progress made to date and explores the hurdles that litter the track ahead as the bell rings to signify the last lap in this race against an ambitious timeframe to produce meaningful outcomes. The finish line is fast approaching, but while the podium, medals and bouquets are being readied, this last lap is sure to be a tough, sweaty slog to completion, and with the volume of work to be done, success could come down to a photo finish.

Which possible outcome of the G20 / OECD BEPS project would carry the biggest fear for your company?