Cost sharing arrangement (CSA)

The first China APA for cost sharing agreement (CSA-APA) focuses on global research and development (R&D) costs and confirms that the R&D costs borne by the taxpayer relating to the development of intangible assets are deductible for corporate income tax purposes and exempt from withholding tax during the eight year period covered by the CSA-APA.

Successfully concluding an APA for a complex issue like CSAs substantially reduces the taxpayer’s transfer pricing risk and future compliance and dispute costs. It also enhances the taxpayer’s confidence to increase investments in developing intangible assets in China and exploit those intangibles in the China market.

How have we helped?

  • Assisted with the first China CSA-APA case.
  • Assisting clients with feasibility and transfer pricing analyses on CSA design and implementation.

Contact us

Jeff Yuan

Jeff Yuan

Asia Pacific Transfer Pricing Services Leader, PwC China

Tel: +[86] (21) 2323 3495

Qisheng Yu

Qisheng Yu

Partner, PwC China

Tel: +[86] (10) 6533 3117

Kevin Tsoi

Kevin Tsoi

Partner, PwC China

Tel: +[86] (20) 3819 2380

Cecilia Lee

Cecilia Lee

Partner, PwC Hong Kong

Tel: +[852] 2289 5690

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