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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While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort