The plan is China's contribution to a global effort to stamp out the common practice of multinationals altering the price put on labor, services or
intangible asset transfers within global operations to allow firms to divert profits to low - tax countries.
CRA provides transfer pricing advice in relation to all types of planning arrangements, including planning for and negotiating advance pricing agreements (APAs), pricing all types of
intangible assets transferred during a business restructuring and analyzing the allocation of risks (and associated transfer prices) between related companies.
Not exact matches
A source at a law firm told the South China Morning Post that the State Administration of Taxation issued a consultation draft on the proposal at the end of last year, specifying that multinationals would have to disclose affiliated businesses and how
intangible assets, labor and other internal cost
transfers were made.»
Similarly an agreed purchase
transfer fee of say # 40m isn't a cost in accounting terms it's an
intangible asset which is written down over the period of the contract.
Disincorporation Relief allows a company to
transfer certain types of
assets (company
assets such as land and buildings, goodwill and other
intangible assets) to its shareholders (who continue to operate the business in an unincorporated form) without the company incurring a corporation tax charge on the disposal of the
assets.
As thought leaders in the areas of
intangible asset valuation,
transfer pricing, and general valuation, we're recognized by corporate clients, lawyers, and tax authorities as offering real value, differentiated thought leadership, and practice advances.
For a business
transfer there would need to be a
transfer of significant tangible or
intangible assets (if the function were
asset reliant) or failing that, a taking over of a major part of the workforce in terms of numbers and skills (if it were labour intensive).
CRA has extensive experience advising multinational clients on the value of their intellectual property, technology, trade names, and other
intangible assets during
transfer pricing proceedings.