Editorial

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Editorial

There is no such thing as a quiet year for China's tax system.

The fifth edition of KPMG's China – Looking Ahead guide shows that all parts of the system covered in previous versions of this publication underwent change in 2015 and more is on the way. For example, Announcement 7 has replaced Circular 698 as the definitive word on the reporting and taxation of indirect offshore disposals, the Special Tax Adjustments discussion draft, covering new transfer pricing guidance and controlled-foreign-company rules, is expected to be finalised before the end of the year, and the transition from Business Tax to a national VAT is expected to be completed in 2016.

Many of the changes are, of course, inspired by, if not taken directly from, the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan, whose final recommendations came out in September 2015. China will have a particularly important role to play in the implementation of the plan in 2016 as president of the G20 group of the world's biggest economies, which commissioned the OECD to reform the international tax system in 2012.

China will be in the global tax politics and diplomacy spotlight for another reason next year. It hosts the next meeting of the OECD-organised Forum on Tax Administration, when more than 100 tax commissioners from around the world will meet in Beijing to discuss ever-constant priorities such as how they can cooperate more and better, and how to resolve disputes quicker and more efficiently.

China wants to use these responsibilities to make a real impact on international tax, but it reserves the right, as it has made clear many times previously, to sculpt any measures according to the needs of its own tax system and economy. For example, it has decided not to adopt, for now, the BEPS proposals on interest deductions and value chain apportionment, the SAT's new transfer pricing method, is nowhere to be seen in the BEPS action plan.

So what does this all mean? It means, to borrow a phrase from a different time, an international tax system in China with Chinese characteristics. It is a situation that taxpayers everywhere will have to monitor closely and we hope the fifth edition of KPMG's China – Looking Ahead will be a valuable tool in helping them do this.

Ralph Cunningham

Managing editor

International Tax Review

more across site & shared bottom lb ros

More from across our site

The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
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
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Gift this article