Our collection of resources based on what we have learned on the ground
Resources
Q&A
What's the definition of related parties in terms of ownership or control under ...
- November 2012
- Free Access
Under Chinese Transfer Pricing Regulations, related parties is defined as follows: One entity, directly or indirectly, holds a total of 25 percent or more of another entity’s shares; or A third party owns or controls, directly or indirectly...
Q&A
How would the indirect shareholdings of a third party in other enterprises be ca...
- November 2012
- Free Access
How do you calculate the indirect shareholdings of a third party in other enterprises under Chinese law?
Q&A
What are the rules for discharging transfer pricing obligations in China?
- November 2012
- Free Access
The nine “Enterprise Annual Reporting Forms for Related Party Transactions of the People’s Republic China” should be submitted, if the enterprise submitting has transactions with related parties that amounts annually to: Below RM...
Q&A
What does contemporaneous transfer pricing documentation mean?
- November 2012
- Free Access
Essentially, contemporaneous transfer pricing documentation is a detailed transfer pricing documentation to support the transactions between the related parties that are at arm’s length.
Q&A
Who is required to prepare contemporaneous transfer pricing documentation?
- November 2012
- Free Access
Parties that do not meet one of the following exemption requirements: Annual amount of related party tangible goods transaction is below RMB 200 million and the amount of the related party intangible goods transactions is below RMB 40 million; Th...
Q&A
What is Advance Pricing Arrangement and who is eligible for such application und...
- November 2012
- Free Access
An Advanced Pricing Arrangement is a multi-year agreement reached with the tax authority on an enterprise’s related transactions pricing principles and calculation method. The benefits normally consist of the following: It resolves transfer ...
Q&A
How does an enterprise apply for Advanced Pricing Arrangement in China?
- November 2012
- Free Access
There are normally 6 stages involved for the application of Advanced Pricing Agreement: Preparation meetings Formal application Examination and appraisal Negotiation Signing of arrangement Supervision and implementation Normally, it takes ...
Q&A
What kind of Advanced Pricing Agreements are available in China?
- November 2012
- Free Access
Unilateral, bilateral and multilateral Advanced Pricing Agreements are available, however, no multilateral Arrangements have been concluded.
infographic
Corporate Income Tax and Minimum Alternative Tax by Business Type in India
- November 2012
- Members Access
For different business types in India, the corporate income tax (CIT) and minimum alternate tax (MAT) are different.
Q&A
What are the types of permanent establishments (PE) in India?
- November 2012
- Members Access
There are three permanent establishments in India, which are as follows: Fixed Place Permanent Establishments - A fixed place of business, with a degree of permanence, at which business is wholly or partially carried out. Agency Permanent E...
Q&A
What are the important concepts in determining a permanent establishment (PE) in...
- November 2012
- Members Access
Important concepts in determining a permanent establishment include: Business Connection - If there is no business connection between a non-resident entity and a resident-entity, the resident entity may not be a permanent establishment of the non-...
Q&A
How to close wholly owned subsidiary (WOS) in India?
- November 2012
- Members Access
A wholly owned subsidiary can be wound up as per the guidelines issued by the act in consultation with Ministry of Corporate Affairs (MCA). The procedural aspects involved in winding up involve: Approval of Shareholders and Creditors; Affidavit f...
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