China (CN)

Jurisdiction Overview

363 *Tax Rulings: Are unilateral cross-border tax rulings (e.g. advance tax rulings, advance tax decisions) available in laws or regulation, or in administrative practice? Yes
 Data Date: 2019


According to the OECD, China can issue unilateral cross-border tax rulings: "cross-border unilateral advance pricing agreements (APAs) covering transfer pricing or the application of transfer pricing principles. The local in-charge tax administration offices are responsible for issuing rulings, with relevant consultation with the Chinese Tax Administration (SAT). Where an APA involves two or more local offices or both the state tax and local tax bureau, the APA process is organised and coordinated by the SAT" (OECD UTR 2018: 101).


OECD UTR 2018: 101
IBFD 2019b