Foreign companies could be caught in China's new indirect transfer rules

February 11 2015

In a strong indication of its growing commitment to enforcing tax compliance, China’s State Administration of Taxation released updated indirect transfer rules to replace Notice 698. Tax professionals say the more stringent tax rules, which include safe harbour regulations, withholding tax obligations of the buyer, and clarifications of reasonable commercial purpose, are both welcome and concerning.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

Pillar two has eroded but not imploded: tax academic

Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour

Sam Sholli, July 30 2026

Transfer Pricing

Brazil’s new customs valuation tools: TP documentation becomes harder to ignore

Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions

William Roberto Crestani, July 30 2026

Direct Tax

Grant Thornton sets eyes on big four with $5bn CBIZ acquisition

The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition

Sam Sholli, July 29 2026

Direct Tax

Talking to Josh Thomas, the entrepreneur's adviser with 128,000 followers

From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders

Tom Baker, July 29 2026

Direct Tax

GAAR in India: substance, purpose, and the limits of legitimate tax planning

Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures

Sanjay Sanghvi, July 28 2026

Direct Tax

Beyond the Headlines: How MHA plans to scale up after revenues soar

Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals

Sam Sholli, July 27 2026

Direct Tax

A taxing week: Country-by-country reporting just became everyone’s business

Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses

Sandy Markwick, July 24 2026

Direct Tax

How integrated FP&A data powers pillar two compliance

Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness

Chris Porter, July 23 2026

Direct Tax

KordaMentha launches tax disputes practice with ATO, PwC Australia hires

Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute

Sam Sholli, July 22 2026

Podcasts

Podcast: What the KPMG Australia scandal means for the big four

ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms

Tom Baker, July 22 2026