Transfer pricing audits in dawn raids china customs often pursues transfer pricing enforcement in the form of dawn raids in an attempt to seize as much evidence as possible before it is tampered with or destroyed and to prevent target companies from colluding with stakeholders. Transfer pricing audit regarding its transactions with its sister companies b ltd china and c inc usa the tax audit focused on the dempe functions in a oy and its sister companies as well as the determination of an arms length compensation for utilisation of intangibles in one of the business units the group. 332 international transfer pricing 2013 14 china peoples republic of audit targets circular 2 provides insight into the procedural aspects of a chinese transfer pricing audit from the tax authorities determining which enterprises will be subject to audit and conducting the audit to issuing a special tax adjustment notice collecting. New transfer pricing requirements in china frequently asked questions o selection and application of transfer pricing methods including rationale and support for selection of transfer pricing method whether the comparable data can support a reliable application of the selected transfer pricing method assumptions and judgments
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