Author： Dr Jian Li（Kunda Tax Consulting (Shanghai) Limited）Source： China Tax Intelligence Standfirst: Since the Action Plan on BEPS was officially revealed by the G20, the SAT has reiterated its determination to strengthen co-operation with the OECD on the BEPS project and has also set forth its general positions to address BEPS issues in China. This … Read more
INTRODUCTION There 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 end result of these key documents is a modern and comprehensive transfer pricing system for China, although certain areas require … Read more
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 … Read more
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 … Read more
Author: Dr Jian Li of Kunda ChinaSourced from Wolters Kluwer China Tax & Accounting Reference Preface Introduction On 13 July 2016, the State Administration of Taxation (“SAT”) released Announcement of the State Administration of Taxation on Matters Relating to Improved Administration of Related Party Declarations and Contemporaneous Documentation (SAT Announcement [2016] No. 42). The announcement … Read more
Transfer pricing laws and regulations The arm’s length principle Identification of related party and the types of related party transactions Transfer pricing methods Comparability Analysis Transfer pricing documentation Related party relationships Related party transactions Comparability analysis Selection and application of transfer pricing method An organizational chart for the company to illustrate the global organisation structure … Read more