The Latest Development of China Transfer Pricing: Legal Framework and Practices

Senior management staff, CFO, CSO, Legal specialist, Financial (Tax) manager, Finance (Audit) staff, etc

This training will not only help you to get a basic understanding of fundamental theories of transfer pricing, to understand the new ruling comprehensively and learn how to meet the new ruling´s compliance requirements, it will also provide guidance and instructions on transfer pricing and tax planning to achieve the balance of compliance and tax efficiency.

Understand the fundamental theories and rules of tax transfer pricing.
The practice, development and lessons of tax transfer pricing for group of company in China.
New taxation law on new regulations, legislative ideas and targeted issues of tax transfer pricing
Basic mode and strategy of transfer pricing arrangement in group of company.
Risk avoidance strategy of tax transfer pricing in group of company.

Award the Shanghai University of Finance and Economics "transfer pricing" Advanced Training Course Certificate of completion.

On Jan 9, 2009, China released its transfer pricing regulation “Implementation Measures of Special Tax Adjustments (Trial Version)” (Guoshuifa 2009, No.2) which has a retrospective effective date as January 1, 2008. This marks the beginning of a new era for China’s transfer pricing regime, which has become more stringent and regulated. For all Chinese enterprises (both listed and private), increased transfer pricing scrutiny and requirements bring increased compliance burden. In the meanwhile, greater legal certainty can also been achieved through well managed transfer pricing policy and arrangements from now on. Thus, it is imperative for taxpayers in China to enhance the understanding on the new TP regulation and take action accordingly.


[Training Contents]

This training will cover all the major points of the new ruling, including Transfer Pricing Filing, Contemporaneous Documentation, Transfer Pricing Audits, Advance Pricing Arrangement, Cost Contribution Arrangement, Thin Capitalization, General Anti-avoidance, Transfer Pricing Planning, etc. In addition, in order to help you to better understand the principles and contents of the ruling, the training will also include the ABCs of transfer pricing like fundamental theories of China transfer pricing, a review of the development of transfer pricing rulings and transfer pricing considerations on intra-group services. Moreover, in order to enhance the practical value of this training and your ability to implement the TP theory with consideration of each company´s specific situation, the training also include an introduction of risk management of transfer pricing.

The detailed agenda of the two-days training is as follows:

1. Fundamental Theories of China Transfer Pricing
Basic Concepts
Functional Analysis and Enterprise Characterization
Transfer Pricing Methods
How to Evaluate the Rationality of Transfer Pricing Arrangements
2. Overview of the New Transfer Pricing Ruling
3. Transfer Pricing Filing and Contemporaneous Documentation
Annual Filing
Requirements and Strategies of Contemporaneous Documentation
Benchmarking
4. Transfer Pricing Audits
Audit Targets
Audit Process
Anti-Auditing Strategies
Case Studies
5. Advance Pricing Arrangement
Process
Strategies and Case Studies
6. Cost Contribution, Thin Capitalization and General Anti-Avoidance
Concept and Practice of Cost Contribution
Cost Contribution in China: History and Current Situation
7. Transfer Pricing Considerations on Intra-Group Services
8. Transfer Pricing Planning
Supply Chain Management
Change of Transfer Pricing Policy
9. Risk Management of Transfer Pricing



Duration of public course is two days; and charge of training is 9800RMB including cost for training, information and tea break. Prices for group or internal training may be discussed in details.