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Transfer pricing

Transfer pricing refers to the pricing of buy and sell, transfer and use of tangible assets, transfer and use of intangible assets, provision of services, financing and other business between related enterprises.

With the issue of China transfer pricing regulations and the improvement of relevant complementary articles and rules, China tax bureaus constantly increase the intensity of transfer pricing investigation, which has been regarded as one of the priorities.

DENCHI not only accumulates a wealth of local practical experience, but also actively shares with customers about transfer pricing trend all over China. We provide your company with transfer pricing documentation preparation, planning and optimization suggestions, investigation defense and disputes settlement, APA and other transfer pricing consulting services.

 Transfer pricing documentation preparation, planning and optimization suggestions 

DENCHI has experienced professionals to assist enterprises to successfully complete transfer pricing documentation in China; during the preparation of documentation, DENCHI will consider both the actual situation of enterprises and the requirements of tax bureaus, and support enterprises’ transfer pricing policies at the utmost.

At the same time, transfer pricing planning become an effective way to actively control transfer pricing risk in related transactions, and it is also one of the necessary way. We will analyze related transactions through in-depth understanding of business operations, functions, risks, assets and the allocation of corresponding costs, expenses and profits, indicate existing problems and risks associated with related transactions from the perspective of transfer pricing, propose rationally professional suggestions, and ultimately probe into the future management of transfer pricing for management’s consideration.

 Transfer pricing investigation response   DENCHI can assist your company to:
  • • Analyze your company's financial situation and transfer pricing policy, develop a favorable defense policy;
  • • Explain to tax bureaus about the advocated transfer pricing policies on behalf of your company, assist your company in the communication with tax bureaus;

DENCHI and the Group - China Tax Advisory Co., Group ("CTAC") have opportunities to communicate with State Administration of Taxation and local tax authorities at all levels. At the same time, our professionals have extensive experience in transfer pricing investigation defense and dispute settlement.


DENCHI can assist enterprises to take precautions, achieve agreement on transfer pricing methods in advance with one or more tax authorities, enable enterprises to more proactively manage double taxation risk and other important transfer pricing issues. In recent years, the achievement of CTAC in APA application and consultation even exceed the Big Four accounting firms.

Professionals in DENCHI and CTAC have engaged in APA for many years and hold a wealth of experience in the field. Among them, Mr. Wang Yukang, the senior partner, used to serve as Deputy Director at International Taxation Department, State Administration of Taxation, in charge of international tax cooperation, tax treaties, information exchange, international anti-avoidance and APA all over China, including leading and participating in the discussion and formulation of important regulations and policies in the areas mentioned above; responsible for quality control of the investigation and settlement of international anti-avoidance case; and participating in the discussion and signature of Sino-Japan, Sino-US, Sino-Korea and other bilateral APA and having played an active role.