China continues to consolidate and improve its transfer pricing system. With the advancement of the Base Erosion and Profit Shifting (BEPS) Action Plan, Chinese tax authorities have leveraged new technologies and big data analysis tools in their administration to tackle increasingly complex tax avoidance arrangements. Taxpayers should take appropriate actions to mitigate the potential transfer pricing risks.

KPMG China’s transfer pricing team provides holistic assistance to enterprises at all stages of transfer pricing strategy and compliance. Our main services include:

  • Annual declaration of related party transactions and three-tier BEPS contemporaneous documentation (i.e. Master File, Local File and Country by Country Report)  
  • Group value chain arrangements, the design and planning of group domestic and overseas related party transaction structure and pricing (including intangible assets planning, group services fee allocation, financing structure arrangements, etc), as well as the application and implementation of transfer pricing methods
  • Effective tax risk management, defense and response to tax investigations and queries
  • Applications for advance pricing arrangements (APA) or mutual agreement
  • BEPS 2.0 related tax impact assessment and planning 
  • Related party equity transfer and intangible asset valuation
  • Economic substance review and shareholder structure restructuring for companies residing in low tax jurisdictions
  • Design and implementation of automatic information systems for related party transactions
  • Construction of group transfer pricing risk management system and procedures