In brief The State Administration of Foreign Exchange (SAFE) recently released the Service Trade Foreign Exchange Management Policy Q&A (part 2)1. SAFE provided clarifications on the bank procedures for processing foreign exchange payments and receipts for transfer pricing (TP) adjustments (hereinafter referred to as “Clarification”). Contents Key takeaways Background Overview…
In brief The State Administration of Foreign Exchange (SAFE) recently released the Service Trade Foreign Exchange Management Policy Q&A (part 2)1. SAFE provided clarifications on the bank procedures for processing foreign exchange payments and receipts for transfer pricing (TP) adjustments (hereinafter referred to as “Clarification”). Contents Key takeaways Background Overview…
In brief After much anticipation, the OECD released the ‘Blueprint’ for their Pillar Two proposal on 12 October as part of its two pillar package to deal with the increasing digitalisation of the economy. The premise behind the Pillar Two proposal is simple, if a state does not exercise their…
In brief The Baker McKenzie Global Tax Team has undertaken an in-depth analysis of the ‘Blueprint’ for the Pillar One proposal to produce a digestible summary of everything you need to know. To read our summary of the Blueprint for Pillar Two please click here. Contents CHAPTER 1 – INTRODUCTION TO…
The impact of COVID-19 has been profound. Companies are facing disruptions to supply chains, customer demand, operations and output, and are being confronted with liquidity concerns. In many cases, governments across the world have announced tax provisions and other programs to dampen economic hardships and free much needed cash resources.…
As the 2019 Novel Coronavirus (COVID-19) continues to spread across the world and restrictions to the mobility of people and goods increase, businesses are facing weakened financial markets, as well as disruption to workplace operations and business pipelines. Tax authorities across the globe have enacted amendments in order to cope…
On 13 July 2016, the State Administration of Taxation finally released the long-awaited Bulletin 421 to revise the transfer pricing documentation requirements under Circular 22.
In late 2009, the PRC tax authorities issued their most influential and also most controversial anti-avoidance tool, Notice 6981, to combat indirect transfers designed by offshore investors to avoid paying the 10% capital gains tax on the direct transfer of equity interests in Chinese resident enterprises. On February 6, 2015,…