While GAAR are new in China taxation, they have made great waves in the past couple of years. The controversial Circular 698 on indirect disposals will be here to stay in one form or another, but not without increasing resistance from foreign corporations and tax administrations. John Gu, Chris Xing and William Zhang of KPMG expect that the SAT may have to provide clearer guidance and explore an advance ruling system as a way to address the concerns of taxpayers.
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Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements
Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions
Wopke Hoekstra also swore the EU would ‘hit back harder’ if faced with a trade war; in other news, a UK watchdog has launched an investigation into an audit completed by MHA