Chinese transfer pricing rules and practices will break new ground in the coming years, finding solutions that cater to the special economic and commercial circumstances of China. Factors such as China market premiums and location savings will become more important in applying the arm’s-length principle, believe Cheng Chi, Irene Yan and Lu Chen of KPMG
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap