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 trialists.

  • 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:, Tel: +44 (0)207 779 8379

Subscribe now

Subscribe today to gain full access to International Tax Review.


Free trial

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

Free trial

International Tax Review Profile

.@HainesWattsLiv makes #DavidWaddington its newest #tax partner

Dec 1 2015 09:15 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Amended Singapore-Russia treaty lengthens time to determine PE, lowers WHT rates on interest, royalties, dividends

Dec 1 2015 05:49 ·  reply ·  retweet ·  favourite
International Tax Review Profile

.@kpmguk #DanielHead becomes new #transferpricing partner in Manchester

Dec 1 2015 03:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

.@MattosFilho Even George Orwell couldn’t have foreseen that the Brazilian #tax authorities would assume this role

Dec 1 2015 01:34 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @shahabhis: @thefirmupdate @FollowCII @followassocham @IntlTaxReview - for God' sake, NO - Middle of the year intro means avalanche of c…

Nov 30 2015 08:02 ·  reply ·  retweet ·  favourite
International Correspondents