In this special edition of Insights: Transfer Pricing, CRA analyzes the regulatory, tax, and transfer pricing issues on the major types of intercompany payments that multinational corporations may have with their subsidiary and affiliated companies operating in China. Through case studies derived from actual examples of multinational corporations operating in China, CRA illustrates practical problems and suggests possible solutions in “Intercompany payments between multinational corporations and their affiliated companies in China.”
OECD issues guidance on transfer pricing implications of COVID-19
The Guidance is not prescriptive and leaves solutions to the issues that it raises unanswered. We note that the Guidance is not binding on tax administrations...