By Chris Devonshire-Ellis, Andy Scott, Sam Woollard
This consultant is an in depth evaluation of all points of move pricing in China. Produced in organization with move Pricing affiliates, a expert international move pricing company, this is often a vital paintings for any businessman buying and selling with or accomplishing enterprise in China. The publication offers with all facets of move pricing from a pragmatic point of view, from designing and enforcing a move pricing procedure, to handling China compliance and getting ready for an audit.
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This consultant is an in depth evaluation of all points of move pricing in China. Produced in organization with move Pricing affiliates, a expert worldwide move pricing company, this is often an important paintings for any businessman buying and selling with or accomplishing enterprise in China. The booklet offers with all features of move pricing from a realistic viewpoint, from designing and imposing a move pricing approach, to coping with China compliance and getting ready for an audit.
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Additional resources for Transfer Pricing in China
Some of the critical issues discussed during the automotive session in June 2010 included: • Local marketing intangibles: if a foreign invested entity performs sophisticated marketing functions in China, the SAT may take the view that these lead to the creation of local marketing intangibles (which need to be rewarded with higher profitability) • Location savings: there is uncertainty about whether some or all of the cost savings gained by a multinational being able to produce in China at a lower price than abroad should be recognised in the China entity or the overseas parent.
These disclosure forms require all taxpayers with related party transactions to disclose a large amount of detail concerning their related party transactions including details of amounts and types of related party transactions, the level of documentation available and methodology used to test the arm’s length nature of the transactions, and the level of profitability on these transactions. 1 Prior to the 2008 tax year companies with related party transactions were required to file a specific disclosure form (either Form A or B) with their annual corporate income tax returns within 4 months after the year end.
However, sources and original record keepers must be quoted. The notes, tape recordings, videos, photographs and copies obtained shall be sealed or stamped, and labeled with ‘‘checked against original documents’’ by the original record keepers or providers 8. Witnesses, if needed, shall be informed of their legal obligations if they do not truthfully provide the information requested. ’’ This means that besides the party under investigation, any company considered comparable is required to provide any information requested by tax authorities.