Download or read book The Chinese Approach to Transfer Pricing written by Jingyi Wang and published by . This book was released on 2017 with total page 31 pages. Available in PDF, EPUB and Kindle. Book excerpt: With the increasing integration of the Chinese market into the global economy, China's tax policy on transfer pricing and its tax administration influence extremely large numbers of cross-border transactions between China and other states. China has suffered heavy revenue loss from transfer pricing manipulation. Since 2008, Chinese tax authorities have paid special attention to such tax avoidance methods. By examining the Chinese approach to transfer pricing based on publicly available information, this article analyses the reasons for the perceived aggressiveness of Chinese tax authorities in dealing with transfer pricing issues, and the inconsistency between the statutory endorsement of the arm's length principle and the approach adopted in practice by tax authorities. Measures to improve the efficiency of the administration of transfer pricing in China are proposed.
Download or read book Transfer Pricing written by Alan Paisey and published by Universal-Publishers. This book was released on 2012 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers an introduction to transfer pricing with particular reference to China, for those who are looking for an overview that can be rapidly comprehended and who value diagrammatic images as a vehicle for learning. The subject is of importance both for Chinese and foreign personnel engaged in foreign company activity in China and for those who are similarly engaged in Chinese-owned companies already operating abroad, or which are to be extended to foreign locations.
Download or read book Transfer Pricing in China written by Chris Devonshire-Ellis and published by Springer Science & Business Media. This book was released on 2011-05-18 with total page 93 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Guide is a detailed overview of all aspects of transfer pricing in China. Produced in association with Transfer Pricing Associates, a specialist global transfer pricing firm, this is an essential work for any businessman trading with or conducting business in China. The book deals with all aspects of transfer pricing from a practical perspective, from designing and implementing a transfer pricing system, to managing China compliance and preparing for an audit.
Download or read book Transfer Pricing in China written by Jian Li and published by Springer. This book was released on 2019-05-30 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers up to date insights into the exciting world of China’s extensive economic activity through the pervasive and often secretive practice of transfer pricing. It begins with an explanation of transfer pricing itself and goes on to explore how intricately it can infiltrate the trading practices of the commercial lives of both foreign companies in China and Chinese companies expanding to other countries. A review of the main industries in China also considers their possible future uncertainties. China has joined other authorities in actively legislating and organizing a regime to implement its arm’s length policy, as related in Part I of the book on concepts and controls. This is then followed by Part 2 which is devoted to a collection of cases showing the breadth and variability of companies actively seeking to maximise their profits, while Part 3 of the book gives a rare record of the order of priorities exercised by one hundred Chinese tax officers engaged in auditing company performance. The book ends with a summary of the future trends, and activities that regulatory authorities are likely to undertake.
Download or read book Transfer Pricing written by Richard Thompson Ainsworth and published by . This book was released on 2019 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: Any contemporary Chinese transfer pricing assessment needs to consider the United Nation (UN) Practical Manual on Transfer Pricing for Developing Countries released in May 2013. In particular, Chapter 10 discusses Country Practices and presents China's most up to date transfer pricing policy statement. China is not an Organization for Economic Cooperation and Development (OECD) member nor has it formally adopted the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Chapter 10 makes it very clear that China is charting a different transfer pricing course in at least nine important areas. China believes that: 1. significant comparability adjustments are needed when comparable sets are drawn from developed countries; 2. the transactional net margin (TNMM) is considered overused and inaccurate; 3. location savings must be reflected in the costs; 4. toll manufacturers will be converted into contract manufacturers; 5. limited risk distributor status is denied for brand building distributors; 6. market premiums must be reflected in Chinese profits; 7. tax haven based IP ownership can be “looked through” or denied; 8. cost-plus methodology is rejected for “high and new technology status” (HNTS) entities; 9. royalty adjustments over time are necessary.The Chinese approach to transfer pricing or at least the approach presented in the Practical Manual uses familiar OECD terminology but it places a very different emphasis on some basic concepts in the OECD Guidelines. Thus, the Chinese market economics strengthens the State Administration of Taxation's hand and encourages more forceful transfer pricing policies. This is the case even though these policies diverge from OECD norms. This paper considers the nine major areas where the Chinese position in the UN Practical Manual differs from positions in the OECD Guidelines.
Download or read book Transfer Pricing Audits in China written by J. Li and published by Springer. This book was released on 2007-01-10 with total page 204 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book focuses on the practice of transfer pricing audits which the Chinese government operates in the case of the vast number of foreign enterprises operating in the Chinese economy. It includes the testimony of Chinese officials about their work, material that given the secrecy of Chinese business and culture, is difficult to come by.
Download or read book Transfer Pricing Disputes in China written by Jinyan Li and published by . This book was released on 2013 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is a relatively new issue in the People's Republic of China. China opened its door to foreign investors in the late 1970s and multinational enterprises brought their transfer pricing practices to China. It was not until 1991 that China enacted the first transfer pricing law. As expected, China imported the arm's length principle to deal with the imported transfer pricing problem. Because the Chinese legal culture differs in many respects from that of OECD countries, especially the United States where the arm's length standard originated, adaptation of the OECD-based solution is inevitable. In addition, China's national interest in cross-border transfer pricing matters have changed over the past three decades, which has led to corresponding changes in China's approach to resolving transfer pricing disputes.
Download or read book Managing Transfer Pricing Risks by Multinational Companies in China written by A. Zhao and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In the past year, the Chinese tax authorities have issued three new circulars to outline their position and approach in dealing with transfer pricing issues. This article seeks to identify the specific areas that are likely to draw heightened attention from the Chinese tax authorities from now on and provides recommendations on how to prepare for the new audit environment.
Download or read book A Rethink of Location specific Advantages with an Analysis of the Chinese Approach written by C. (X.) Peng and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article aims to provide an overview of the current debate on location-specific advantages (LSAs) and their implications for the future of transfer pricing research. With a special focus on the Chinese approach to LSAs, it compares the views of the OECD, the United Nations and the United States. Furthermore, it analyses LSAs from a conceptual, economic and transfer pricing perspective. In particular, this article identifies three issues arising from the LSA debate, namely the conflict between taxing MNEs and the arm's length principle, the data constraints on local comparables and the increased concerns regarding marketing activities.
Download or read book International Taxation in China written by Jinyan Li and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
Download or read book Transfer Pricing in China written by Steven Carey and published by . This book was released on 2009 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 written by OECD and published by OECD Publishing. This book was released on 2009-08-18 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.
Download or read book China s Grand Strategy written by Andrew Scobell and published by Rand Corporation. This book was released on 2020-07-27 with total page 155 pages. Available in PDF, EPUB and Kindle. Book excerpt: To explore what extended competition between the United States and China might entail out to 2050, the authors of this report identified and characterized China’s grand strategy, analyzed its component national strategies (diplomacy, economics, science and technology, and military affairs), and assessed how successful China might be at implementing these over the next three decades.
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.
