China’s Circular 146 challenges OECD’s cross-border guidelines with broader TP analysis

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China’s Circular 146 challenges OECD’s cross-border guidelines with broader TP analysis

The issuing of Circular 146 by the State Administration of Taxation (SAT) highlights the Chinese tax authorities’ increasing efforts to enforce transfer pricing (TP) administration for cross-border charges. Taxpayers with significant amounts of cross-border charges should conduct internal audits to avoid getting caught out.

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