Transfer Pricing
转让定价 — Transfer pricing rules and documentation requirements
Transfer Pricing 转让定价
Legal Basis
- Enterprise Income Tax Law, Art. 41–44 — special tax adjustment provisions
- Implementation Measures for Special Tax Adjustments (特别纳税调整实施办法) — Bulletin [2017] No. 6
Arm's Length Principle
Transactions between related parties must be conducted at arm's length. The tax authorities may make adjustments if transfer prices do not reflect fair market value.
Documentation Requirements
Three-Tier Documentation
- Master File (主体文档) — group-wide overview
- Local File (本地文档) — detailed local entity TP analysis
- Country-by-Country Report (国别报告) — CbCR
Filing Thresholds
Documentation requirements depend on the volume of related-party transactions.
Advance Pricing Arrangements (APA)
Enterprises may apply for unilateral, bilateral, or multilateral APAs with the STA to achieve certainty on transfer pricing methodology.
TP Methods
- Comparable Uncontrolled Price (CUP)
- Resale Price Method
- Cost Plus Method
- Transactional Net Margin Method (TNMM)
- Profit Split Method
To be expanded with specific STA bulletins and practical guidance.
Tax Incentives
税收优惠 — Preferential tax policies for enterprises and foreign investors
👉 STA Documents
STA interpretation documents related to transfer pricing and advance pricing arrangements
2026 © Denis Shushin.
Disclaimer: The content presented on this website is intended for informational purposes only and does not constitute legal advice. Laws and regulations may change, and the information provided may not reflect the most current legal developments. We encourage visitors to consult a qualified legal advisor before making any decisions based on this content.