China formally announces its transfer pricing position

Tax Insights ()

The State Administration of Taxation (“SAT”) has announced its position on transfer pricing practices in China with the release of its paper, China Country Practices (“the paper”).  The paper forms part of Chapter 10 on Country Practices in the United Nations’ Practical Manual on Transfer Pricing for Developing Countries (“UN Transfer Pricing Manual”). 

The paper marks a significant development as it represents the SAT’s views and practices on a number of transfer pricing challenges faced by China, as a developing country, which are not addressed by the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD Transfer Pricing Guidelines”).