Related parties
Cross-border and domestic related-party transactions of FIEs.
China Law Key Words · Tax and Fiscal Compliance
Transfer Pricing in China
Keyword hub for China transfer pricing—related-party filings, documentation, and substance for intercompany goods and services.
Last reviewed 21 August 2026
The rule in 60 seconds
Start with the rule, then map it to your situation
This briefing separates the core issue from the next research and counsel steps.
Contemporaneous files
Local file / special issue readiness when thresholds hit.
Key distinction: This is general orientation. Company type, documents, location and timing can change the analysis.
Which situation are you in?
Start with the event, then test the rule
Scenario 01
Related parties
Cross-border and domestic related-party transactions of FIEs.
Next review: Open the related guides and confirm how this issue presents in your documents.
Scenario 02
Contemporaneous files
Local file / special issue readiness when thresholds hit.
Next review: Open the related guides and confirm how this issue presents in your documents.
Scenario 03
HQ recharges
Management and service fees need evidence of benefit.
Next review: Open the related guides and confirm how this issue presents in your documents.
Scenario 04
Audit themes
Loss-making distributors and royalty-heavy models draw questions.
Next review: Open the related guides and confirm how this issue presents in your documents.
Key steps
A simple sequence for this topic
01
List related-party flows
Goods, services, royalties, loans.
02
Test benefit of HQ fees
Who received what.
03
Prepare TP narrative
Functions, assets, risks.
04
Align contracts & invoices
Paper matches substance.
Review checklist
What to check before you choose the next step
List related-party flows
Goods, services, royalties, loans.
Test benefit of HQ fees
Who received what.
Prepare TP narrative
Functions, assets, risks.
Align contracts & invoices
Paper matches substance.
Watch losses + royalties
Classic audit combination.
Why this matters
The issue usually reaches beyond a single filing
Related parties
Cross-border and domestic related-party transactions of FIEs.
Contemporaneous files
Local file / special issue readiness when thresholds hit.
HQ recharges
Management and service fees need evidence of benefit.
Audit themes
Loss-making distributors and royalty-heavy models draw questions.
Recommended reading path
Move from the rule to the right depth of guidance
Common situations
Recognise the issue before you choose the response
Related parties
Cross-border and domestic related-party transactions of FIEs.
Contemporaneous files
Local file / special issue readiness when thresholds hit.
HQ recharges
Management and service fees need evidence of benefit.
Frequently asked questions
Questions readers commonly need answered next
Is TP only for large multinationals?
Smaller FIEs with HQ recharges still face related-party disclosure and substance questions.
Parent?
Tax & fiscal hub.
Guides & articles
Practical writing from counsel and the portal editorial team on this topic
When the next step needs advice
Turn the legal issue into an actionable company plan.
Use the directory to find relevant counsel or ask a focused question through China Legal Portal.