Tax Implications of Transfer Pricing Payments for Service Fees and Royalties
The State Administration of Taxation (SAT) recently asked provincial-level tax authorities to investigate companies who transferred profits out of China through large deductible payments such as service fees and royalties between 2004 and 2013. Local tax authorities should report their findings by Sept. 15, and launch tax audit procedures on companies that are suspected of tax avoidance.
This development is consistent with several high-profile tax cases in China where tax deductions on sizable outbound service fees and royalties were denied on various grounds. In view of this government initiative, the AmCham China Tax Forum is hosting a panel discussion on the SAT investigation, providing insights on the implications to multinational companies, and offering recommendations to mitigate tax and transfer pricing adjustment risks for historical and future periods.
The panelists are specialists in PRC tax and transfer pricing, representing the Big 4 accounting firms as well as industry.