China's State Administration of Taxation (SAT) has submitted its views and provided two recommendations for the next update of the United Nations Practical Manual on Transfer Pricing.
Views
The SAT confirms its view that service fees paid and received between related parties must be in compliance with the arms length principle, and that the tax authorities are empowered to make adjustments if transaction are non-compliant.
It also confirmed its view that management fees as defined under Chine…