TP · 04 Editorial guide
China Transfer Pricing and Intercompany Service Fees
Transfer pricing is a related-party file. It is not a dividend withholding form.
First job Name the related-party flows before treating TP as a generic CIT question.
Start here
Key considerations
The first questions are about urgency, governance and preservation — before collection expands or interviews begin.
- Which related parties and flows?
- Is documentation, adjustment, or audit response the job?
- Does CIT still need its own route?
Direct answer
What this page decides
02
This page owns TAX04 documentation and TAX05 intercompany services. Related parties, transaction types, local/master/special files and contemporaneous documentation are the file. Service fees need substance, benefit, agreements and deliverables — not a management-fee invoice. Royalties and loans have their own tests. Customs valuation of royalties/assists is Trade (TC07). WHT/VAT on the fee is Tax characterisation plus Repatriation. No documentation-threshold RMB amounts printed here.
At a glance
Which fact changes the next route
Use the fact that changes ownership or urgency to decide the next move.
| Question | Why it matters | Next route |
|---|---|---|
| Management fee with no people? | Benefit test. | Services row. |
| Royalty also in the customs value? | Trade valuation L4. | |
| Need APA? | Counsel; not this page’s default. |
Scope
What this page owns — and what it does not
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| List related parties and flows | Ownership, contracts, invoices | Complete map | RP inventory |
| Match documentation duties | Current STA thresholds | Do not use last year’s slides | File plan |
| Test services | Agreement, timesheets, deliverables | Benefit and duplication | Service file |
| Align WHT/VAT/FX pack | Invoices, treaties, bank | Repatriation + Banking | Payment pack |
Documents
What to gather before the next call
These items help clarify the file; they are not a legal requirement list.
| Item | Why needed | Who holds it | Risk if missing |
|---|---|---|---|
| Local/master file if required | Duty | Tax | Late file |
| Service deliverables | Benefit test | HQ/ops | Fee denied |
Common failure points
Where files usually break
Invoicing 5% of sales as ‘support’ with no work product.
TP report that contradicts the customs value file.
FAQ
Narrow follow-ups owned by this page
What are the documentation thresholds?
Current STA rules only. Supporting: /china-transfer-pricing-basics.
Decision map
Keep the question bounded.
- Map the flowsGoods, services, intangibles, financing — at a high level.
- Name the fileLocal file, contemporaneous docs, or a dispute.
- Keep remittance separateCash exit belongs on the clearance route.
Quick answers
Need the short version? Start with one narrow question.
These explainers answer one question. They do not replace this topic route or a deep guide.
Curated resources
Open the asset that matches this job.
Helpful to prepare
Facts that make the next conversation clearer.
These items are orientation aids, not a legal requirement list.
Counsel hand-off
What to bring when you instruct
Instruct TP counsel. Bring: related-party map, contracts, and last local file if any.
Local context
Add the city when bureau practice changes.
Filing portals, fapiao practice and clearance queues vary after the national tax question is identified.
Open city and province guidesCounsel hand-off
Need tax counsel?
This hub organises tax files and clocks. It does not compute tax, grant clearance or file a return on your facts.
Find tax counselLegal review
Who reviewed this guide
Subject to editorial/legal review. No reviewer is assigned to this route.
Need qualified counsel?
Move carefully. Move with a record.
Use the portal to identify counsel for this practice and related China-side issues.