China – Looking Ahead is a series of articles that examines the implications for tax of China's 12th Five-Year Plan. These articles look at how the tax system might change if it is to fulfill the goals of the 5YP, which include wealth distribution, increased domestic consumption and regional development. The articles also analyse key tax policy areas such as transfer pricing, green taxation, VAT and property.
Asia Transfer Pricing provides insights into the transfer pricing developments across Asia. Jurisdictions with more developed transfer pricing rules have been extending their scope to cover interrelated areas (such as customs) while countries that are relatively new to transfer pricing are increasing their knowledge all the time.
Hong Kong
This article discusses the recent developments to the transfer pricing landscape in Hong Kong and outlines how these indicate that the SAR is willing to provide its IRD with the appropriate tools to fight against a potential erosion of its tax base.
As time passes, Hong Kong transforms its approach to international tax towards a more transparent, OECD-compliant model with the negotiation and the signing of numerous DTAs. These changes, together with the recent issuance of DIPN 46 clearly provide the IRD with mechanisms for dealing with transfer pricing issues.
China
Transfer pricing regulations in China are considered comprehensive and one of the most extensive and demanding in the world, particularly in relation to contemporaneous documentation requirements. In 2010, a number of important transfer pricing developments took place in China.
This article discusses these recent transfer pricing developments as well as provides comments on how potential exposure to related party transaction within multinational corporations can be assessed, managed and alleviated in People's Republic of China.
|
