This seminar will introduce the latest transfer pricing developments and trends in China in the wake of BEPS and the recent (draft) China Chapter of the new version of the United Nations Transfer Pricing Manual for developing countries as well as the recent Bulletin 6, third and final bulletin in a series through which the State Administration of Taxation (SAT) has comprehensively revised the transfer pricing regime under the former Circular 2. Bulletin No. 6 key provisions and their implications for multinational companies (MNCs) will be analysed.
Since the publication of the United Nations Practical Manual on Transfer Pricing for Developing Countries in 2013, China has been actively involved in the G20/OECD BEPS project, which aims to reform international tax rules in order to prevent MNCs from artificially shifting profits to low tax jurisdictions. This seminar will analyse current transfer pricing trends in China, including audit activity, advance pricing agreements with tax authorities, challenges to sales structures and IP planning, among other issues. The session will touch upon both policy issues, such as legislation overhaul, intensified audit activity and SAT capacity building, as well as substantive matters such as supply chain implications, IP and treatment of location specific advantages (“LSA”).
In this context, on 17 March 2017, the State Administration of Taxation (SAT) issued the Bulletin on the Administrative Measures for Special Tax Investigation and Adjustments and Mutual Agreement Procedures ("Bulletin 6"). Bulletin 6 is the third and final bulletin in a series through which the SAT has comprehensively revised the transfer pricing regime under the former Circular 2. Once Bulletin 6 has taken effect on 1 May 2017, the revamping of China's transfer pricing regime will be complete. Bulletin 6’s key directives, including value contribution analysis for intangibles, intragroup outbound payments, location specific advantages, transfer pricing method and toll manufacturing will be clarified. Hereinafter, the impact of Bulletin 6 on multinational companies’ (MNCs’) transfer pricing planning and audit defense will be analysed and discussed to provide recommendations to MNCs on how to develop appropriate transfer pricing strategies to safeguard their tax interests in China.”
Agenda:
08:30 – 09:00 Registration
09:00 – 09:10 Introduction by Ms. Anna Ding, Finance & Taxation Working Group National Chair, Tax Vice Director, BASF
09:10 – 09:35 Presentation, ‘Transfer Pricing on China. Latest issues and trends’, Mr. Rafael Miraglia, Senior Tax Manager Global Transfer Pricing Team, KPMG
09:35 – 10:00 Presentation, ‘Bulletin 6 or the Revamping of China’s Transfer Pricing Regime’, Mr. Ning Liu, Senior Economist, Baker&McKenzie
10:00 – 10:40 Discussion Panel with the following participants confirmed:
Mr. Rafael Miraglia, KPMG
Mr. Ning Liu, Baker&McKenzie
Mr. Jeremy Gong, Tax Director, Bosch
10:40 – 10:50 Q&A
10:50 – 11:00 Closing remarks by Ms. Anna Ding
Payment:
You can pay at the day of the event using cash or local debit/credit cards. The European Chamber can give you an official fapiao for amount exceeding 200 RMB, and this will be sent to you via courier a few days after the event.
Terms & Conditions:
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