The recent tax anti-avoidance regulations issued by the State Administration of Taxation (“SAT”) have showed that the Chinese tax authorities are seriously targeting taxpayers undertaking abusive tax arrangements without commercial substance (including the application for treaty benefits).
In recent weeks, the Chinese tax authorities have actively requested taxpayers to submit the 2008 and 2009 Transfer Pricing Contemporaneous Documentations ("TPD reports") based on the requirements stipulated in Guo Shui Han [2010] No.323. To drive the quality-review initiative, the local tax authorities are required to record and report the quality of TPD reports based on the scoring system set up by the SAT.
In this seminar, we will discuss how the Chinese tax authorities apply the anti-avoidance concepts in recent transfer pricing investigations, share real life cases and our experiences on how taxpayers could manage or mitigate the transfer pricing exposures in China.
PricewaterhouseCoopers' transfer pricing specialists will address the recent development of transfer pricing landscape in China including:
Implications and insights from recent TPD collection and review enforcement; Transfer pricing investigation and self-assessment trend in China and our insights on the latest technical concepts / arguments applied by the Chinese tax authorities. For instance, equity transfer among related entities, economic characterization of High New Tech Enterprise (“HNTE”), outbound royalty arrangement, marketing intangibles, costs / location savings, China market premium, etc; Recent development of Advance Pricing Arrangement (APA) and Mutual Agreement Procedure (MAP) in China; The SAT / local tax authorities’ key anti-avoidance initiatives in the coming years.
Speaker
Charles Chan - Transfer Pricing Senior Manager, PwC
Charles has/is...
...actively assisting MNC clients in identifying their TP issues, handling TP documentation, TP tax audits defence support and liaising with Chinese tax officials in obtaining APAs.
...wide experience in liaising and negotiating with local Chinese tax bureaus located in Southern China, such as Shenzhen, Nansha, Dongguan and Fuzhou.advise clients on APA application / tax audit defence support strategies in light of Chinese tax bureau’s practices.
...regularly supports and conducts interflow sessions with various professional bodies and tax bureaus in Hong Kong and Southern China region.
Venue
PwC Wutong Conference Room,58/F
Shun Hing Square
Di Wang Commercial Centre, 5002 Shennan Road East
How to register?
Please confirm your participation by email to
Ms. Sophie Wen at
gz.intern@euccc.com.cn
Members : 100 RMB
Nonmember: 200 RMB
Privilege Members of the European Chamber Pearl River Delta Chapter
Event Terms & Conditions
Please note that, though all are welcome to attend our events, we strongly recommend that you register via email with us in advance so that we can keep you updated on any changes in the event schedule. From time to time, due to unforeseen circumstances we need to change the time or venue of an advertised event. So please do let us know by registering online if you plan to attend an event so that we can keep you informed.
To register for this event please register via email to Ms. Sophie Wen at gz.intern@euccc.com.cn by 6:00pm Tuesday, 7th September. Please note that we will send you a registration confirmation. We require 24 hours notice for cancellations. For any further enquiries or registration, please contact us at gz.intern@euccc.com.cn
Fees will be collected in cash at the entrance.
Please be advised that the media is normally allowed to attend all EUCCC public events unless otherwise stated, on the condition that no one attending these events quotes participants by name (the "Chatham House Rules").