The announcement of the China Country Practices, as part of the UN Practical Manual on Transfer Pricing for Developing Countries (draft version), indicates a great leap in the transfer pricing (TP) administration of the State Administration of Taxation (SAT). Han Jin Ping, tax manager at Siemens, China, discusses the importance of the chapter and the international message it conveys on contract R&D.
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The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems