This product aims at providing multinationals a very practical and informative guide to transfer pricing in China and globally and so help create potential tax saving opportunities with proper planning and efficient implementation.

• Written by top transfer pricing experts (TPA global partner and senior manager in TPA greater China).
• Based on China but with wide global perspectives to provide a very practical and informative guide to transfer pricing in China and globally.
• Thoroughly and authoritative comments on the new TP regulation of Guoshuifa [2009] No.2 – Implementation Measures for Special Tax Adjustment (Trial Implementation).
• Abundant of real-world cases analysis and useful OECD, China regulations comments and also provides a lot of transfer pricing implementation templates.

Contents Includes:

chapter 1. Managing your Transfer Pricing Globally

• The transfer pricing process
• Transfer pricing methods
• Economic analysis
• Documentation
• Transfer pricing risk assessment
• Dispute resolution
• Global transfer pricing developments

chapter 2. Transfer pricing in China

Based on Guoshuifa [2009] No.2, this Chapter provides detail and authoritative comments on the issues related to transfer pricing like declaring for related party transaction, preparing for contemporaneous documentation, managing a transfer pricing audit and conducting an APA etc:

• Relevant laws on transfer pricing in China
• Confirmation of associated enterprises and arm’s length principle
• Transfer pricing adjustment method
• Advance Pricing Agreement (APA)
• Information disclosure and penalties
• Approaches of prevention and resolution on transfer pricing dispute

chapter 3. Dealing with Special Transfer Pricing Issues

• Global business model
• Intangibles
• Management service
• Financial transactions

chapter 4. Transfer Pricing Cases

This chapter analysis eight famous real-world internationally and domestic cases all in the framework of:

• Points of the case
• Facts of the case
• Illustration
• Issues arising
• Findings

chapter 5. Regulations and Templates

This chapter includes comprehensive transfer pricing regulations and templates which are useful for the practitioners to borrow ideas, such as:

• Summary of OECD Guidelines
• EU JTPF Code of Conduct
• Transfer Pricing in Key Trading Partners
• Checklist for taxpayers
• Designing the transfer pricing system
• TPA Tool – Masterfile template
• Proforma APA application
• China laws and regulations related to transfer pricing

Product Includes:

• One loose-leaf Subscription
• To insure that your copy is always current four times updates annually will be issued when there are major developments. And they are all free.
• Monthly Newsletter ( China Tax & Accounting Watch in Chinese and biweekly PRC Briefing in English, both emailed to desktop)