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Transfer Pricing

Transfer pricing is becoming an increasingly important topic for companies around the world, fueled among others by initiatives such as the BEPS (Base Erosion and Profit Shifting) Action Plan by the OECD as well as local guidelines, regulations and best practices.

China’s transfer pricing regime, albeit China not being a member of the OECD, is largely following recommendations by the OECD, where China has implemented via Bulletin 41 (2016) numerous rules and regulations on transfer pricing including requirements for transfer pricing documentation as set out in the BEPS Action Plan 13. All transactions between the headquarters of a multinational group (or other related parties) and its Chinese subsidiary should be conducted based on an arm’s length principle.

The Chinese transfer pricing regime consists out of two distinct aspects:

Related party transactions:

All resident enterprises in China must file annual reporting forms for related party transactions, and these forms must be prepared and submitted together with the annual CIT filing. Furthermore, enterprises engaging in a cost sharing arrangement with related parties must complete the special file by June 30^th of the next fiscal year.

Detailed transfer pricing documentation:

Those enterprises who exceed relevant transaction thresholds are required to complete detailed transfer pricing documentation, including a) Master File and b) Local File.

To learn more about transfer pricing in China read our article on Transfer Pricing in China.

Our Transfer Pricing Services

Through our association and global partnerships, we leverage our international and local tax specialists to provide our clients complete transfer pricing solution, including planning, compliance and documentation support as well as advisory on tax efficiency and reducing non-compliance risks. In cooperation with our partners, we are able to offer our clients a comprehensive transfer pricing service offering including:

Support with the initial setup and updating transfer pricing documentation, including Local File and Master File.
Benchmark studies.
Transfer pricing policy design and implementation.
Drafting and executing intercompany agreements.
Advisory on Chinese foreign exchange regulation.

Testimonials

MSA has been our trusted advisor throughout the entire lifecycle of our China journey, enabling us to dispatch employees (EOR) to China while having no legal entity and the incorporation and operationalization of our Chinese subsidiary. After this, MSA continues to prove its value as an advisor in supporting not only Chinese accounting, taxation, and compliance requirements but also by advising on specific licensing requirements within the horticulture industry in China, such as those for trading in pesticides and other chemicals. With a profound understanding of our headquarters’ interests and a thorough understanding of local business practices in China, MSA has enabled us to balance the often-conflicting requirements for control and compliance with our ambitious China growth strategy.

Royal Brinkman

Vincent Van Der Wilk
Area Manager Asia & Africa at Royal Brinkman

For our fast-growing business, we need a reliable partner to handle all our payroll-related matters, which we found in MSA. They helped us streamline our internal processes by implementing and improving compliance processes from a legal perspective and in terms of our corporate policies. We fully trust in the confidentiality of our employees’ data, as they ensure secure data storage from internationally recognized providers. Whether on ad-hoc requests or long-term oriented recurring matters, we always receive a fast and complete response to our questions that help us achieve our compliance goals and overcome the challenges in payroll, IIT, and social security in China.

Genuine German

Damian Maib
Founder

MSA was our first choice when we were looking for a China-based accounting firm with a fundamental understanding of our Belgian background and the ability to connect two diverging business cultures. As our company operates with the corporate ERP system Oracle, we are delighted that MSA works through proprietary access directly in our system, ensuring the availability of our company figures in the format we are accustomed to. During our company’s setup procedure, they managed to organize particular steps without the personal presence of the company representatives (e.g., opening a bank account) by identifying alternative verification procedures. We appreciate that MSA always listens to our queries. They are very well connected both within China and internationally. In addition to our questions about our China business, we are glad to receive advice on questions about other international topics from their connections within their global network.

Hybrid Software

Joachim Van Hemelen
Chief Financial Officer

MSA has been an exceptional business partner for our company, whom have a thorough understanding of our internal processes and our ERP system. As a result, and combined with their expertise in finance and taxation, they have been able to support Feinmetall by training our finance- and administrative staff to ensure quality standards and compliance throughout all areas. Because of their availability on short notice, we can rely on MSA’s support at a moment’s notice if required. We further rely on MSA to follow our monthly business on site in China in terms of accounting, taxation, and general compliance. Ensuring full compliance with local regulations and transparency for our management team in Germany is essential and MSA is our trusted partner helping us achieve this.

Feinmetall

Patrik Dinser
Commercial Director

From day one of our collaboration, I have found the team at MSA perfect for our needs. As a UK based business with notable activities in the Far East, we are looking for clear, constructive and accurate advice along with of course day to day financial/fiscal support. This is exactly what we get, and this provides enormous reassurance over the numbers and furthermore excellent support as we grow our business in the Far East. A true partner to our business in every sense of the word.

Badgequo Ltd.

Matt Goldstein
Finance Director

MSA has been our trusted service provider since the establishment of our operations in China. With a profound understanding of Chinese compliance requirements and the ability to translate these requirements in an international context, MSA has enabled us to achieve an exceptional level of transparency and an understanding of the Chinese financial and administrative regulations. After the expansion of our operations in China we continue to rely on the expertise of MSA in relation to taxation matters. MSA continues to reserve dedicated staff members, with a thorough understanding of our operations, whom are ready to support our local finance team in a heartbeat should the need arise.

Lotus Bakeries NV

LOTUS BAKERIES CHINA

MSA is our advisor of choice for complex tax and financial advisory with respect to our China operations. MSA’s team of experts has supported us with extensive advice on various topics such as international transactions, tax implications and business structure optimization. We trust on the company’s knowledge and experience to make well-informed decisions that are key to our company’s success in China. Most notably, MSA’s solid advice and practical support has enabled us to successfully optimize our internal business structure, which included among others comprehensive advice on the optimal business structure for CIBES’ operations in China and subsequent support from MSA with the implementation of the new structure (incl. establishment of 40 branches across Mainland China).

Cibes Lift Group AB

Manuel Neuhofer
Director of Finance and Administration for ASIA & MENA CIBES Lift Group