China APA stats

Just in case you’re interested in these things: last month, China’s State Administration of Taxation (“SAT”) published its annual report on Advance Pricing Arrangements (APAs). The report covers the period from 2005 to 2017.

According to the report, China’s APA programme still deals primarily deals with inbound MNE applicants. Here are the numbers of new APAs signed with China over the last 5 years:

2013 – 19

2014 – 9

2015 – 12

2016 – 14

2017 – 8

All the APAs involving China have been either unilateral or bilateral, with no multilateral APAs. Although there have clearly been significant fluctuations from year to year, the SAT has apparently now provided additional internal resource for APA work, and it can be expected that the numbers will increase. Nevertheless, in common with the position for other tax authorities, the absolute number of MNEs benefitting from APAs remains low, no doubt reflecting the large investment of time and effort (and patience) required for these processes.