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2014

Boston University School of Law

International Law

Transfer pricing

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Transfer Pricing: Un Practical Manual – China, Richard Thompson Ainsworth, Andrew Shact Jan 2014

Transfer Pricing: Un Practical Manual – China, Richard Thompson Ainsworth, Andrew Shact

Faculty Scholarship

Any contemporary Chinese transfer pricing assessment needs to consider the United Nation (UN) Practical Manual on Transfer Pricing for Developing Countries released in May 2013. In particular, Chapter 10 discusses Country Practices and presents China’s most up to date transfer pricing policy statement.

China is not an Organization for Economic Cooperation and Development (OECD) member nor has it formally adopted the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Chapter 10 makes it very clear that China is charting a different transfer pricing course in at least nine important areas. China believes that: 1. significant comparability adjustments are …