Transfer Pricing Services

Transfer pricing is another challenge for international businesses with operations in China. The increased volume of cross-border transactions has made transfer pricing becoming a complicated issue. Transfer pricing audits in China can result in retroactive review of up to ten years. With the Chinese authorities tightening their grip on transfer pricing enforcement with additional resources and regular audits, businesses must act accordingly to prevent adverse predicaments that may potentially result in heavy fines and additional tax payments. Hong Kong tax authority also issued Transfer Pricing Guidelines (Methodologies and Related Issues) for strengthening the management on transactions between associated companies.

To cater for our client’s needs, we have developed our international tax team and are experienced in handling tax group structuring and transfer pricing tax planning as well as documentation. We helped our client on tax planning to reduce their international tax burden and tax risk as well as on tax challenges proposed by the tax authorities.

China is definitely one of the jurisdictions which have close business relationship with Hong Kong companies. Our PRC tax team can advise client on their PRC tax exposure as well as cross-border transactions and arrangements between Hong Kong and the PRC.

We, a specialized tax team with professionals experienced in wide range of taxation areas, can assist you in the following areas:

• High-level review
• Transfer pricing benchmarking
• Assisting in contemporaneous documentation preparation
• Advisory services on preparing transfer pricing group master file
• Supply chain transfer pricing advisory services
• International transfer pricing advisory services (e.g. cost sharing arrangement, contract research and development, and intangible asset planning)
• Advance pricing arrangement advisory services
• Advisory on transfer pricing audit defense