In brief The State Administration of Foreign Exchange (SAFE) recently released the Service Trade Foreign Exchange Management Policy Q&A (part 2)1. SAFE provided clarifications on the bank procedures for processing foreign exchange payments and receipts for transfer pricing (TP) adjustments (hereinafter referred to as “Clarification”). Contents Key takeaways Background Overview…
In brief The State Administration of Foreign Exchange (SAFE) recently released the Service Trade Foreign Exchange Management Policy Q&A (part 2)1. SAFE provided clarifications on the bank procedures for processing foreign exchange payments and receipts for transfer pricing (TP) adjustments (hereinafter referred to as “Clarification”). Contents Key takeaways Background Overview…
Companies want and need to take action to deal with the uncertainty caused by COVID-19, or to take measures to enable their operations to weather possible outbreaks or similar events in the future. Those actions have transfer pricing implications, and if companies have an Advance Pricing Arrangement (APA), or are…
The adverse consequences of COVID-19 could be broad, including reduction of consumer demand, supply chain disruption, and an increase in risk aversion in financial markets (driven by an overall downturn in business and consumer confidence). Local subsidiaries of multinational enterprises (MNEs) in affected regions, even those that are operating “business…
On 13 July 2016, the State Administration of Taxation finally released the long-awaited Bulletin 421 to revise the transfer pricing documentation requirements under Circular 22.
In late 2009, the PRC tax authorities issued their most influential and also most controversial anti-avoidance tool, Notice 6981, to combat indirect transfers designed by offshore investors to avoid paying the 10% capital gains tax on the direct transfer of equity interests in Chinese resident enterprises. On February 6, 2015,…