The New China Country Practice Chapter of the UN Practical Manual on Transfer Pricing: Reflections on Post-BEPS Transfer Pricing in the Middle-Kingdom

In this article, the authors critically analyse the China Country Practice Chapter inserted into the United Nations Practical Manual on Transfer Pricing for Developing Countries in 2016. They present a critique of the major transfer pricing challenges facing China and the purported solutions to them. In this context, the article gives an overview of the strategies and practice developments of China’s State Administration of Taxation, addressing conceptual gaps and linking the tax administration’s policy statements to its enforcement practice.