China’s Transfer Pricing Rules

Abstract

China’s transfer pricing legislation was first enacted in 1991. The same transfer pricing rules have also been incorporated into the tax collection law since 1992, effectively broadening the applicable scope of transfer pricing to all taxes in China. Several tax rules and circulars have been announced since then to assist with their implementation. To reinforce the regulatory framework, the State Administration of Taxation issued specific implementing measures between 1992 and 2005. From time to time, the State Administration of Taxation has also issued notices urging local tax authorities to strengthen transfer pricing enforcement.