China: Implementation rules for transfer pricing administration (Macau)
Effective January 1, 2026
The government of China’s Macau Special Administrative Region (Macau SAR) in August 2025 officially issued Implementation Rules for Transfer Pricing (Administrative Regulation No. 11/2025).
The rules further refine Macau SAR’s transfer pricing regulations, aiming to improve transparency and align local tax laws with international anti-tax avoidance standards. The rules became effective on January 1, 2026, and apply to all controlled related-party transactions from that date.
Background
The Macau SAR government on December 16, 2024, introduced a transfer pricing regime, clarifying the concept of transfer pricing and the principle of related-party transactions, and requiring that transactions between taxpayers in Macau SAR and their related parties in other tax jurisdictions must comply with the arm’s length principle. The implementation rules provide detailed and specific guidelines on the application of the arm’s length principle, methods for transfer pricing adjustments, requirements for the retention of controlled transaction documentation (i.e., transfer pricing compliance documents), and advance pricing arrangements (APAs).
Read a February 2026 report prepared by the KPMG member firm in China