Transfer Pricing & Supply Chain Taxation

Transfer Pricing & Supply Chain Taxation - China

Reducing your risks in a complex environment

Multinational organisations, including Chinese state-owned enterprises (SOEs) are operating in an environment of unprecedented complexity. As many corporations focus on transfer pricing as a tax management strategy, enforcement activities are increasing worldwide.

China in particular is scrutinising such arrangements very closely. Given the recently released OECD/G20 BEPS (base erosion and profit shifting) action plan, much more stringent and consistent tax rules will apply to all companies operating in China.

By ensuring that transfer pricing solutions fit your overall global operations and objectives, our lawyers reduce your risks. We also assist with documentation to support transfer pricing practices, and advise you on resolving disputes efficiently.

Everything you need to know about transfer pricing

Our law firm’s tax team is particularly strong in transfer pricing. We have proven capacity and hands-on experience in providing the full range of transfer pricing services. These include advice on transfer pricing policy, benchmark analysis, preparing documentation, audit defence and negotiation.

We have had notable success representing clients in the largest and most challenging transfer pricing audit and negotiation projects. And we are frequently consulted on planning strategies, documentation, advance pricing agreements (APAs), and other matters of transfer pricing and supply chain law.

We also plan, implement and defend your supply chain structures. We do this by taking into account your commercial objectives, the allocation of value attributes, the relevant indirect tax or tariff costs and the bonded processing trade model.

We advise multinational corporations, state-owned enterprises and private companies across the full range of market sectors on:

  • Transfer pricing policy including providing technical analysis
  • Transfer pricing planning and documentation
  • Business model optimisation    
  • Transfer pricing audit defence
  • Negotiation with tax authorities on transfer pricing disputes
  • Responding to challenges or audit by customs authorities
  • Negotiating with customs authorities on customs, processing trade or supply chain related issues.

Discover our latest insights into legal issues affecting your business

What is the trend of regulation of domestic related-party transactions under Bulletin 42?

26 September 2016

Based on the 2014 Compliance Plan on International Tax Administration, the new 2016 Plan covers fourteen areas.

14 September 2016

China’s State Administration of Taxation has issued Bulletin 42, the implementation and localisation of BEPS Action 13, which will bring considerable challenges for taxpayers.

21 July 2016

This article seeks to provide a high level overview of transfer pricing, with a specific focus on HK and transactions between China and HK enterprises.

26 November 2015