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China: Simplified process for unilateral advance pricing arrangements

Baker McKenzie

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China September 29 2021

In brief

The State Taxation Administration (STA) recently released Bulletin [2021] No. 241 ("Bulletin 24"), introducing new simplified process for the administration of unilateral advance pricing arrangement (UAPA).

Key takeaways

  • The Chinese tax authorities are increasingly willing to accelerate the APA process to confirm compliance with arms' length principle of related party transactions.
  • Bulletin 24 introduces new simplified process for UAPA with fewer steps, specified timeline and one-off submission of application documents to achieve efficiency and tax certainty for multinational companies (MNCs).
  • The simplified UAPA process could serve as a useful and practical tool for MNCs to manage their TP risks.
  • The simplified process is not one-size-fits-all. We would encourage MNCs to engage professional tax advisors to assess if they would be able to take advantage of the simplified UAPA process.

 

Content is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee similar outcomes. For more information, please visit: www.bakermckenzie.com/en/client-resource-disclaimer.

Baker McKenzie - Nancy Lai, Jinghua Liu, Abe Zhao, Jason Wen, Shanwu Yuan, Brendan Thomas Kelly, Amy Huai Chih Ling and Jon Eichelberger

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