Transfer pricing

Fast-moving changes and significant regulatory developments

Managing risk in the global economy

In an ever-changing global economy, Transfer Pricing (TP) is one of the most important tax issues for multinational companies. With more than 3,000 professionals in over 80 countries, PwC's transfer pricing network of teams is well-positioned to advise you on a strategy that can help advance your goals within the ever-shifting compliance landscape.


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An increasing focus on transparency

Managing transfer pricing risk remains critical in an increasingly transparent business environment, and as the Base Erosion and Profit Shifting (BEPS) debate leads to greater international tax regulation and review.

In an effort to tackle tax BEPS, China’s tax authorities have been focusing on transfer pricing administration by enforcing stringent local-flavoured transfer pricing regulations, imposing detailed compliance requirements and invoking ever-increasing scrutiny on related party transactions.

Taxpayers in general would want to avoid letting a tax dispute turning into an investigation. Companies should therefore assess their risks and document their transfer pricing policies in their China operations. No matter what your industry is, we have the tools, the local presence and the sophisticated, up-to-date regulatory knowledge to help you stay ahead of the game.

Market focused services


Our service approach is built upon industry specialisation to align with clients’ expectation of our professionals in understanding their business. Professionals from our automotive team are determined to deliver lasting values for you and your business as they continue to stay up to date with current practices and emerging trends.

PwC’s automotive clients include OEMs, parts suppliers and other notable companies in the automotive value chain. Although each of these companies operates differently, but they often face common issues and challenges such as supply chain management, cost reduction management, globalisation and marketing etc.

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Financial services

Our team has developed technically robust and implementation-ready support across the wide variety of instruments and operations that are impacted by financing and related treasury transactions for multinational organisations. The team includes specialists with deep technical and controversy experience covering the entire spectrum of intercompany treasury transactions, including loans, cash pooling, guarantees, etc.

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Investments in healthcare on a global level are substantial and continue to grow. While businesses focus their efforts locally, an important way to drive more effective growth and change in the market is by capitalising on best practices and knowledge gained cross borders.

Although challenges in the healthcare industry can vary between regions, healthcare systems around the world have the same objective: to finance and deliver the highest possible quality of care to the maximum number of people at the lowest possible cost. As a consequence of these common priorities, solutions are evolving that transcend borders and cultures.

PwC's experience and expertise goes beyond geographic and functional boundaries. We have an understanding of healthcare systems and the dynamics that drive them. With a global network of firms that advise governments and private enterprises on every aspect of business performance, we apply intellectual capital developed in engagements around the world, locally and across industries to our clients' most complex problems.

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Industrial products

The industrial products sector represents some of the most dynamic multinational organisations across diverse industries. These industries impact our daily lives which include energy, utilities and mining, engineering and construction, transportation and logistics among others. Within our transfer pricing team, a dedicated group of professionals specialise in working with these industries and seeing to their specific needs.

As one of the major providers of transfer pricing services, we provide transfer pricing insights and tailored solutions to address your unique business needs and any issues that you may have.

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Retail and consumer

The outlook for China’s retail and consumer markets remains buoyant and, in an increasingly digital and global economy, today’s retail industry is continuously evolving. Major retailers are seeing innovation, talent, technology and having competitive edge as keys to future growth while cyber security and data privacy are considered two of the biggest challenges.

Our specialised retail and consumer professionals in the transfer pricing team in China have an extensive network coverage of the market in Greater China. PwC provides services to over 80% of retail and consumer companies meaning that we have the market expertise and knowledge to stay ahead of game in fulfilling customer needs.

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Telecommunications, media and technology (TMT)


Against the backdrop of rapid technology innovations and tumultuous changes in the industrial landscape both in China and globally, the telecommunication industry is on the brink of a major change which will impact the supply chain of all market players.

Media and entertainment

The media and entertainment industry is experiencing both opportunities and challenges presented by the digital transformation requiring a shift from traditional business models to businesses, brands and revenue streams that leverage on digital content and platforms.


The technology industry is witnessing disruptions at a rapid pace with the introduction of artificial intelligence, Internet of things (IoT), 3D printing, blockchain and more. China is at the forefront of these innovations in technology.

To help businesses in the TMT industry foresee the risks ahead and navigate through complex challenges, we are dedicated to providing our clients with professional transfer pricing advice from strategy to implementation based on the latest industry trends.

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Contact us

Jeff Yuan

Asia Pacific Transfer Pricing Services Leader, PwC China

Tel: +[86] (21) 2323 3495

Qisheng Yu

Partner, PwC China

Tel: +[86] (10) 6533 3117

Kevin Tsoi

Partner, PwC China

Tel: +[86] (20) 3819 2380

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

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