What 转让定价 means
Chinese tax authorities may review pricing for related-party goods, services, financing and intangible transactions. Methods include comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split, among others.
Transfer pricing should be coordinated with customs valuation, intercompany contracts, functional analysis and contemporaneous documentation; inconsistent positions across regulators can create risk.
Where you see the term
Translation note
转让定价 is “transfer pricing”. It refers to pricing between related parties for tax purposes, not a corporate equity transfer.
Primary legal basis
Example
A China distributor earns a persistently low margin while paying large service fees to its parent. The tax authority may test whether the related-party pricing reflects the functions and risks in China.
Primary authorities.
18 Sep 2026