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
Kevin Tsoi is a Director of PricewaterhouseCoopers specialising in the Chinese transfer pricing regime. He joined PwC in 2000. Kevin has been actively involved in assisting clients in defending transfer pricing audit cases, reviewing and evaluating transfer pricing risks, rationalising transfer pricing policies, and applying for unilateral and bilateral APAs. Kevin also contributes to professional publications on the development of the China transfer pricing environment. He is a frequent speaker on the subject for professional seminars and conferences. He earned his Master of Business Administration and Master of Business Taxation degrees from University of Southern California.
Agenda:
16:00 – 16:30 – Registration
16:30 – 17:30 – Presentation on Transfer Pricing and Relevant Documentation
17:30 – 18:00 – Q&A
18:00 – Business Networking
How to register?
Please confirm your participation by email to Ms. Michelle Wen at prd@euccc.com.cn
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. Michelle Wen at prd@euccc.com.cn by 19th October. 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 prd@euccc.com.cn
Fees will be collected in cash at the entrance.
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