Landmark MAP and APA Case Concluded by Competent Authorities in 2012

On 31 July 2012, China’s State Administration of Taxation (SAT) reached agreement in principle with the competent authority of a treaty country on a landmark case involving transfer pricing matters. This article summarizes China’s transfer pricing regulations relevant to the case, and provides a brief history and background of the case and the authors’ view on the case and on China’s outlook on anti-avoidance matters.