China Takes the Lead on Transfer Pricing Policy: Combating BEPS Through a Value Chain Analysis

Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global, and Ying van Galen Wang is a project manager with the firm.

China’s State Administration of Taxation on June 29, 2016 issued a new transfer pricing regulation - Bulletin 42, which replaced specific sections stipulated in previous transfer pricing circulars2 in relation to annual filing of related-party transactions and contemporaneous transfer pricing documentation.

Bulletin 42 represents a new milestone in China’s efforts to combat tax avoidance through transfer pricing. Since the project to combat tax base erosion and profit shifting (BEPS) initiated by the Organization for Economic Cooperation and Development and the Group of 20 countries in 2013, China has been one of most active countries in Asia to support the BEPS project’s development and implementation.

Throughout the country, various levels of the local tax authorities have been working to adapt the OECD guidance and recommendations into tax measures in order to equip themselves to face the tax avoidance challenges in their local tax administrations.

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