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