China: Transfer Pricing

Global regulatory frameworks are rapidly evolving to enhance transparency around offshore wealth structures through beneficial ownership registration regimes and enhanced corporate disclosure requirements. As tax authorities gain unprecedented access to information about ultimate controllers and economic beneficiaries behind complex offshore entities, individual investors face increasing scrutiny of their cross-border investment arrangements and compliance obligations.

This comprehensive bulletin examines recent tax developments across Asia, including China's VAT reforms, India's controversial Supreme Court ruling on treaty protection, Japan's 2026 tax reform package...

The Macau Special Administrative Region of the People's Republic of China ("Macau SAR") government officially issued the "Implementation Rules for Transfer Pricing" (Administrative Regulation No. 11/2025)...

WTS showcased some practical means for the management personnel or controllers to identify and manage tax risks in these areas.

Glenn DeSouza, transfer pricing leader in Dentons' Shanghai office, examines China's transfer pricing regime as outlined in three bulletins, the most recent of which was issued in March.

China signed the MLI on 7 June 2017. It has opted out of the MLI's permanent establishment (PE) provisions concerning (i) artificial avoidance of PE status through commissionaire arrangements and similar strategies;

By now many multinational companies have begun the process of addressing how Financial Accounting Standards Board Interpretation No. 48 ("FIN 48") will apply to their global business.

Since the early 1990s, China has maintained a dual income tax system for foreign invested enterprises ("FIEs") and domestic enterprises. Preferential tax treatment like lower tax rates, tax deductions and tax holidays offered to FIEs was designed to attract foreign investments to China.

The recent passing of the 'Renewables Law' is set to turn China into a global heavyweight in the future development of the renewable energy sector.