Transfer Pricing Audits of Service Fees: Are You at Risk?

The Chinese tax officials are now more active and aggressive in the realm of transfer pricing. Multinational companies should take proactive steps to understand and shape their transfer pricing models and tackle potential risks. This article illustrates the large transfer pricing adjustment made by the Chinese tax authority pertaining to service fees paid to Singapore […]

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Avoiding the China Cash Trap

Although Announcement 40, promulgated in July 2013, simplifies outbound remittance procedures, some issues still await to be addressed. In this article, we explore the tax implications of outbound service fee and royalty payments, and examine the authenticity and reasonableness aspects and present the remittance procedures and supporting documents required with respect to service fee and […]

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Implications of the New Transfer Pricing Guidelines in China and Practical Measures for Multinationals to Adopt in 2009

IntroductionThere have been seismic developments in the transfer pricing field in China in the past year with the promulgation by the State Administration of Taxation (SAT) of the following important legislation and guidance: • “The Corporate Income Tax Law of the People’s Republic of China” (hereinafter referred to as the “Corporate Income Tax Law”) issued on […]

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FAQs – China Transfer Pricing

Table of Contents Transfer pricing laws and regulationsWhat are the laws and regulations on transfer pricing in China?The arm’s length principleWhat is the arm’s length principle?What are the issues in the actual application of the arm’s length principle?Identification of related party and the types of related party transactionsWhat is the definition of a related party?What […]

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Publications

“Transfer Pricing – A Practical Guide” by CCH (co-authored by Dr Jian Li of Kunda China) This bilingual guide of Transfer Pricing-A Practical Guide will provide helpful information and practical guide for the taxpayers to manage its global transfer pricing strategy, design its transfer pricing systems and make risk assessment and contingency evaluation. “Transfer Pricing Audits in […]

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China Transfer Pricing Documentation Handbook

Author: Dr Jian Li of Kunda ChinaSourced from Wolters Kluwer China Tax & Accounting Reference Quick Navigation PrefaceIntroductionThe HandbookChina Transfer Pricing PracticesRegulatory DevelopmentsSpecific Issues and High-Risk TransactionsEnforcement ActivityRecommendationsA Summary of Documentation and Disclosure RequirementsDefinition of Related PartyTax Return DisclosuresLevel of DocumentationLanguage for documentationDeadline to Prepare DocumentationDeadline to Submit DocumentationStatute of limitationsTransfer pricing methodsComparablesContent requirementsMaster File:Local […]

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