SAT wants 500 transfer pricing specialists
May 04, 2010
A Chinese tax official has revealed plans to broaden the scope of the country’s anti-avoidance agenda and also provided important statistics from 2009.
At KPMG’s Transfer Pricing Summit on April 23 in Beijing a senior transfer pricing official at China’s State Administration of Taxation (SAT) provided some insights into developments in the technical position of the Chinese head tax authority. Of particular interest, the official said that the SAT is challenging the prevalence of the transactional net margin method (TNMM) in transfer pricing studies, especially where it is not based on sound functional and risk analysis as well as comparable analysis. Instead the SAT is advocating the profit split method (PSM) at least in cases where it can provide a sanity check for complex issues such as transfers of intellectual property (IP).
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