First unilateral APA signed in Beijing
June 11, 2009
The economic and technological development zone office of the Beijing Municipal State Tax Bureau (BSTB) has signed its first unilateral advanced pricing agreement (APA) after various rounds of negotiations.
The BSTB said on its website that it would be continuously and cautiously responsive to current and future APA applications submitted by taxpayers. While on one hand, the BSTB will actively respond to taxpayers' APA applications, on the other hand it will review them carefully, specifically focusing on comparability analysis and industry analysis in respect of, for example, major assumptions, transfer pricing policy and methodologies.
As Beijing is the location of the Chinese headquarters of many foreign-based multinational companies, the BSTB is anticipating an increasing number of APA applications and has increased its number of anti-avoidance tax officials to cope with this. The bureau is also in the process of forming a bilateral APA negotiation team. The BSTB has five bilateral APAs in negotiation. The BSTB expects that the recent conclusion of its first unilateral APA will have a positive impact on the application and conclusion of future APAs in Beijing.
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