China Transfer Pricing

One of the highlights of the Enterprise Income Tax Law (“EIT Law”) effective as of 1 January 2008 is that it is the first time that the “Special Tax Adjustment Rules” is set out, under which the principles of the tax treatment of the related party transactions and the anti-avoidance are provided. It releases the signals that the state intends to strengthen the administration of the related-party transaction and anti-avoidance. The practice of the tax collection and administration of the tax authorities in recent years also demonstrate it. And tax amount collected from transfer pricing adjustment is increasing year by year.
For enterprises with huge related party transaction amount, especially those falling with the industries that the state shall focus to make the tax audit, it is particularly important to strengthen the preventive management of the related party transaction.
The transfer pricing team of M&T Lawyers will provide the following services:
  • Risk assessment of the enterprise’s TP policies
  • TP policies formulation and management
  • Supply chain planning
  • Contemporaneous documentation preparation
  • Support for response and defense in TP audit
  • Advance pricing arrangement (“APA
  • Draft and review of the cost sharing agreement
  • Support in other anti-avoidance cases