Transfer Pricing Alert Issue No. 2022001 - China's State Taxation Administration released its COVID-19 transfer pricing guidance

The International Taxation Department of China's State Taxation Administration (STA) released the "Response to Questions Relating to Anti-Tax Avoidance Issues During the COVID-19 Pandemic" on 30 September 2021 via the STA official website. The guidance has considered the impact of the COVID-19 pandemic on taxpayers’ business operations and related party transactions, and provided transfer pricing (TP) guidance on the following five aspects: 

  • Principles for conducting transfer pricing audit
  • Considerations of losses incurred by enterprises who were negatively impacted 
  • Key considerations of local file documentation preparation
  • Impact of government assistance on transfer pricing
  • Impact on the execution of existing advance pricing arrangements (APAs)

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