Transfer Pricing Report - China
Take Control of Transfer Pricing China for Tax Clarity & Total Tax Compliance.
Providing world-class transfer pricing services in China aligned with the country’s evolving LCITA regulations, documentation standards, benchmarking requirements, and audit expectations.
Our China -focused TP advisory ensures your intercompany transactions remain arm’s-length, risk-proof, and compliant with OECD Transfer Pricing Guidelines.
Trusted by Cross-Border Businesses — 95% Project Success in the China
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Our Expertise in China Transfer Pricing Benchmarking & Compliance
In-Depth Regulatory Knowledge
Audit-Proof Documentation
Strategic Transfer Pricing Advisory
Multi-Jurisdictional Coverage
Achieve Complete Transfer Pricing Compliance in China
China enforces one of Asia’s most comprehensive Transfer Pricing regimes, requiring taxpayers to maintain Local File and Master File documentation and, where applicable, a full Transfer Pricing study.
All cross-border related-party transactions must be supported by robust benchmarking and economic analysis in line with State Taxation Administration (STA) requirements and OECD Transfer Pricing Guidelines.
5000+
Transfer Pricing Documentation
Our Commitment: Precision, Compliance & Global Consistency
We help China-based entities and multinational groups operating in China prepare defensible Transfer Pricing documentation that withstands scrutiny from the State Taxation Administration (STA).
Strategic Compliance
Financial Strategy
A Simple Process for Transfer Pricing Documentation & Benchmarking
Risk & Policy Assessment
Documentation & Benchmarking
Ongoing Compliance & Support
Experienced Transfer Pricing Advisors at Your Service
Answers to Your Transfer Pricing Concerns China
Get clarity on the most common questions our clients ask about international transfer pricing services.
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Yes. China requires eligible taxpayers to prepare Local File, Master File, and Special Issue documentation, along with annual Related-Party Transaction (RPT) disclosures. Contemporaneous documentation must be maintained to mitigate penalties and audit exposure under State Taxation Administration (STA) rules.
Benchmarking in China involves comparing related-party transaction margins or prices with independent comparable companies or transactions, using China or Asia-Pacific data where available. This supports arm’s length pricing in accordance with Chinese TP regulations and OECD Transfer Pricing Guidelines.
Benchmarking is performed through a detailed functional and risk analysis, selection of the most appropriate TP method, and use of reliable comparables. Adjustments may be required to reflect China-specific market conditions and regulatory expectations.
China broadly aligns with the OECD Transfer Pricing Guidelines, but applies its own interpretations and administrative practices. Chinese tax authorities place strong emphasis on value creation, substance, and location-specific advantages.
A China Transfer Pricing study is typically required for cross-border related-party transactions, including goods, services, royalties, financing, and cost-sharing arrangements that meet statutory thresholds or present elevated risk.
Depending on thresholds and transaction types, companies may need to prepare:
- Local File
- Master File
- Special Issue File (e.g., cost sharing, thin capitalization)
- Annual Related-Party Transaction (RPT) forms
China Transfer Pricing – Free 30-Min Consultation
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Diejing Road, Haizhu District, Guangzhou, 510320