Difficulties in Pressing Forward Advance Pricing Agreement (APA) in China

Abstract

With the promulgation of the new Corporation Income Tax (CIT), the APA concept has been enacted into the tax laws. The detailed implementation rules to the CIT supports this APA framework and the proposed transfer pricing requirements to be released soon likely will exempt taxpayers with APAS from certain transfer pricing documentation requirements. But there are still some difficulties which hold back APA from pressing forward in China. This paper analyzes the difficulties and brings forward some measures to solve the difficulties.