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In this issue, you will find:

  • Introduction
  • Transfer Pricing
    • New Transfer Pricing Documentation Rules Introduced to Implement BEPS Country-by-Country Reporting
    • New Rules on APA Administration: Signs of Hope or Greater Challenges Ahead?
    • New Internal Government Procedural Rules on Transfer Pricing Audits
    • Updated China Chapter of the UN Practical Manual on Transfer Pricing for Developing Countries
    • Transfer Pricing Audit Cases
      • Qingdao Case: Transfer Pricing Adjustments to Outbound Royalty Payments
      • Anshan Case: Transfer Pricing Adjustment on Service Fees
  • Anti-avoidance and Non-residents
    • Indirect Transfer Cases
      • Haidian Case: 15 Non-resident Enterprises Taxed on Indirect Transfers
      • Daxing Case: Tax Bureau Allocated the Value of Foreign-owned Trademark to Chinese Entity
    • Treaty Benefit Cases
      • Wuzhong Case: Hong Kong Company Denied Treaty Benefits for Dividends
      • Huzhou Case: Tax Bureau Applies Beneficial Ownership Test to Treaty Benefits for Capital Gains
    • PRC Tax Authorities Increase Scrutiny on Service PEs
  • Enterprise Income Tax
    • New Rules on Super Deduction of R&D Expenses
    • New Rules Regarding the HNTE Recognition
      • New HNTE Recognition Rules
      • New Guidelines for HNTE Recognition
    • TASE Tax Incentives Extended to More Pilot Zones and Service Sectors
    • Yantai Case: Offshore Upstream Merger Disqualified from Notice 59 Exemption
  • Turnover Tax
    • Bye-bye BT! Comprehensive VAT System to Cover All Industries
    • New VAT Exemption Measures
  • Exchange of Information
    • China Signs the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information
    • China Signs the MCAA for Automatic Exchange of CbC Reports
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