中国双边APA数量首超单边 税收确定性护航高水平开放
Zhong Guo Jing Ying Bao·2025-12-05 12:35

Core Viewpoint - The increasing number of bilateral Advance Pricing Agreements (APAs) in China reflects a structural breakthrough in international tax cooperation, providing greater tax certainty for multinational enterprises operating in China [1][2]. Group 1: APA Trends and Data - From 2005 to 2024, China has signed a total of 335 APAs, with 170 being bilateral, marking a significant shift as bilateral APAs have now surpassed unilateral ones [1]. - In 2024, China signed 39 APAs, continuing the upward trend from 2023, with 12 unilateral and 27 bilateral agreements [1]. - The number of bilateral APAs in the intention phase for 2024 has reached 70, an increase of 10 from the previous year, indicating a growing preference among multinational companies for bilateral agreements to mitigate double taxation risks [1][2]. Group 2: Regional Focus and Implications - Approximately 70% of bilateral APAs signed from 2005 to 2024 were with Asian countries, highlighting China's role as a hub for regional tax coordination [3]. - The 27 new bilateral APAs in 2024 include 19 focused on Asia, along with agreements with Europe (6) and North America (2) [3]. Group 3: Support for Enterprises - The Chinese tax authorities are prioritizing the processing of bilateral APA applications for "going out" enterprises, which is expected to enhance the tax certainty for these companies in their international operations [2][3]. - Companies are encouraged to choose between unilateral and bilateral APAs based on their business characteristics, agreement networks, and cost-effectiveness [3]. Group 4: Recommendations for Enterprises - For enterprises primarily facing tax risks within China, unilateral APAs are recommended as a simpler tool, while bilateral APAs are suggested for those with complex cross-border transactions to avoid international double taxation risks [4]. - The value of APAs as a tool for providing tax certainty is expected to be increasingly recognized by enterprises amid rising global economic uncertainties [4].