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中国税务快讯:APA签署效率提高,双边APA受跨国企业青睐
KPMG· 2025-12-02 00:43
Group 1: APA Signing Trends - In 2024, China signed a total of 39 APAs, comprising 12 unilateral and 27 bilateral agreements, showing an increase from 36 APAs in 2023[8] - The number of bilateral APAs signed in 2024 included 22 new agreements and 5 renewals, with 70 bilateral APAs in the intention stage, up by 10 from 2023[8] - The completion rate for APAs in China was 24.20% in 2024, significantly higher than the global average of 18.1%, ranking seventh among reported jurisdictions[8] Group 2: International Cooperation and Industry Focus - From 2005 to 2024, 170 bilateral APAs were signed, with 118 (approximately 70%) involving Asian countries, 33 (20%) with European countries, and 18 with North America[8] - The manufacturing sector remains the primary focus for APA services, with 22 cases involving tangible assets, 12 involving intangible assets, and 8 involving services[8] - The transaction net profit method was the most commonly used transfer pricing method, applied 328 times (83.9% of cases), while other methods were also utilized[8] Group 3: Future Outlook and Compliance - The inventory of bilateral APAs reached 177 cases in 2024, an increase of 28 from 2023, indicating a trend towards stricter acceptance and review processes[11] - Companies are encouraged to submit comprehensive and accurate documentation to expedite the APA application process, particularly focusing on value chain and market premium analyses[11] - Chinese tax authorities are actively enhancing international tax cooperation, with 23 transfer pricing MAP cases concluded in 2024, reflecting a commitment to dispute prevention and resolution[11]