China signed 19 advance pricing arrangements (APAs) — 11 unilateral APAs and 8 bilateral APAs — in 2013, according to the State Administration of Taxation’s (SAT) annual APA report.
The report, released December 5, provides data on China’s APA program from 2005–2013, outlines the process for obtaining an APA in China, provides forms and schedules needed to apply for an APA, and provides contact information for SAT officials responsible for APA requests.
The report revealed that China signed more APAs in 2013 than in the other years reported. Total APAs signed from 2005–2013 was 104 — 67 unilateral APAs and 37 bilateral APAs, the report said.
Of the eight bilateral agreements signed in 2013, five were signed with Asian countries, two were signed with European countries, and one was signed with a North American country. Four bilateral APAs were renewals.
The report said that 12 of the 18 APA agreements signed in 2013 took less than one year to complete. Five agreements took between one and three years to conclude, and two agreements took more than three years. Most agreements involved the manufacturing industry.
By December 31, 2013, the SAT had 82 APA requests that were not yet to be officially accepted,the report said. Accepted APAs totaled 36, and 3 APAs were agreed to but not yet signed.
The most common transfer pricing method applied from 2005–2013 was the transactional net margin method (TNMM).
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