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Observations and Recommendations on Recent Trends in Macau Transfer Pricing
P391/2024 – 14 May 2024
The Macau Special Administrative Region ("Macau"), being located in the core area of the Guangdong-Hong Kong-Macau Greater Bay Area ("the GBA"), is closely connected with the People's Republic of China ("China") and the Hong Kong Special Administrative Region ("Hong Kong"). As an international free trade zone with a relatively simple and stable taxation without any foreign exchange control policies, Macau is favoured by many multinational enterprises (“MNEs”), making it one of the popular destinations for foreign investments.
Whilst Macau has to date not yet issued any formal transfer pricing (“TP”) regulations, it is however committed to improving its tax regulatory system with reference to international standards - which include joining the OECD/G20 Inclusive Framework on BEPS in 2016 and abolishing the tax exemption rules for offshore business with effect from 1 January 2021.
Recently, we have observed that the Macau Financial Services Bureau (i.e., Macau Tax Authority, the “FSB”) is increasingly interested in and has been conducting tax enquiries and investigations in relation to related party transactions conducted by taxpayers as well as the TP policies, in particular on local Macau subsidiaries of an MNE group. This article highlights the Macau tax regulations related to TP and summarizes our observations on the practical application of such, as well as our recommendations thereto.
(English version)
2024
P391/2024 – 14 May 2024
Observations and Recommendations on Recent Trends in Macau Transfer Pricing
[English] [Simplified Chinese]
P385/2024 – 21 February 2024
New customs discretion benchmarks promote clarity
[English] [Simplified Chinese] [Japanese]
P384/2024 – 7 February 2024
China: updates to multiple catalogues of items subject to export controls
[English] [Simplified Chinese] [Japanese]
2023
P380/2023 – 11 October 2023
Customs voluntary disclosure program updated guidance published
[English] [Simplified Chinese][Japanese]
P370/2023 - 13 January 2023
Latest draft VAT law published
[English] [Simplified Chinese] [Japanese]
P369/2023 - 12 January 2023
China Customs announces its Tariff Plan for 2023 and the Catalogue of Dual-Use Items and Technologies Subject to Import and Export License Administration for 2023
[English] [Simplified Chinese] [Japanese]
2022
P358/2022 - 11 July 2022
Guidance updates on customs voluntary disclosure
[English] [Simplified Chinese] [Japanese]
P355/2022 - 8 June 2022
China invites public comments on draft regulations on export control of dual-use items
[English] [Simplified Chinese] [Japanese]
P353/2022 - 19 May 2022
Shenzhen customs and tax authorities announce transfer pricing collaboration
[English] [Simplified Chinese] [Japanese]
2021
P346/2021 - 7 December 2021
Chinese Customs announced measures to implement the RCEP's rules of origin
[English] [Simplified Chinese] [Japanese]
P345/2021 - 30 July 2021
Unilateral Advance Pricing Arrangements Newly Added Simplified Procedures to Improve the Efficiency of Negotiation and Signing between Enterprises and Tax Authorities
[English] [Simplified Chinese] [Japanese]
P343/2021 - 12 July 2021
Global Minimum Tax Frequently Asked Questions (FAQ)
[English] [Simplified Chinese] [Japanese]
P342/2021 - 16 June 2021
Stamp Tax Law Adopted
[English] [Simplified Chinese] [Japanese]
P330/2021 - 11 January 2021
European Union - Mandatory Tax Reporting (DAC6) implemented
[English] [Simplified Chinese]
2021
P346/2021 - 7 December 2021
Chinese Customs announced measures to implement the RCEP's rules of origin
[English] [Simplified Chinese] [Japanese]
P345/2021 - 30 July 2021
Unilateral Advance Pricing Arrangements Newly Added Simplified Procedures to Improve the Efficiency of Negotiation and Signing between Enterprises and Tax Authorities
[English] [Simplified Chinese] [Japanese]
P343/2021 - 12 July 2021
Global Minimum Tax Frequently Asked Questions (FAQ)
[English] [Simplified Chinese] [Japanese]
P342/2021 - 16 June 2021
Stamp Tax Law Adopted
[English] [Simplified Chinese] [Japanese]
P330/2021 - 11 January 2021
European Union - Mandatory Tax Reporting (DAC6) implemented
[English] [Simplified Chinese]
2021
P346/2021 - 7 December 2021
Chinese Customs announced measures to implement the RCEP's rules of origin
[English] [Simplified Chinese] [Japanese]
P345/2021 - 30 July 2021
Unilateral Advance Pricing Arrangements Newly Added Simplified Procedures to Improve the Efficiency of Negotiation and Signing between Enterprises and Tax Authorities
[English] [Simplified Chinese] [Japanese]
P343/2021 - 12 July 2021
Global Minimum Tax Frequently Asked Questions (FAQ)
[English] [Simplified Chinese] [Japanese]
P342/2021 - 16 June 2021
Stamp Tax Law Adopted
[English] [Simplified Chinese] [Japanese]
P330/2021 - 11 January 2021
European Union - Mandatory Tax Reporting (DAC6) implemented
[English] [Simplified Chinese]
2020
P326/2020 - 11 November 2020
China issues 2019 Advance Pricing Arrangement Annual Report
[English] [Simplified Chinese] [Japanese]
P324/2020 - 22 October 2020
China passes export control law
[English] [Simplified Chinese] [Japanese]
P320/2020 - 17 August 2020
New legislation on city maintenance and construction tax and deed tax passed
[English] [Simplified Chinese]
P317/2020 - 27 July 2020
European Union - Mandatory Tax Reporting for certain cross-border arrangements
[English] [Simplified Chinese]
P313/2020 - 8 April 2020
Non Performing Loans – Is this the right timing for foreign investors?
[English]
P310/2020 - 23 January 2020
Guidance issued on individual income tax treatment of foreign-source income
[English] [Simplified Chinese]
2019
P308/2019 - 16 December 2019
Guidance issued on 2019 IIT annual filing requirements for comprehensive income
[English] [Simplified Chinese] [Japanese]
P307/2019 – 9 December 2019
Focus on China Tax Legislation - Draft Consumption Tax Law Released
[English] [Simplified Chinese] [Japanese]
P306/2019 – 9 December 2019
Hong Kong, Macau, Taiwan residents to participate in social insurance program in Mainland China
[English] [Simplified Chinese] [Japanese]
P305/2019 – 2 December 2019
Draft VAT law consolidates, streamlines existing rules
[English] [Simplified Chinese] [Japanese]
P303/2019 – 6 December 2019
STA Issues New Measures for Claiming Treaty Benefits – From "Filing Documents for Record" to "Retaining Documents for Follow-up Administration"
[English] [Simplified Chinese] [Japanese]
P302/2019 – 8 November 2019
OECD's public consultation document: Secretariat Proposal for a "Unified Approach" under Pillar One
[English] [Simplified Chinese] [Japanese]
P301/2019 - 1 November 2019
PBOC reforms calculation of loan prime rate
[English] [Simplified Chinese] [Japanese]
P297/2019 – 6 August 2019
The fifth protocol was signed to further amend the 2006 Arrangement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
[English] [Simplified Chinese]
P293/2019 – 8 April 2019
Chinese Customs will apply new requirement on declaration of dutiable royalties from 1 May 2019
[English] [Simplified Chinese] [Japanese]
P292/2019 – 22 March 2019
VAT reduction policy package introduced
[English] [Simplified Chinese] [Japanese]
P291/2019 – 18 March 2019
Individual income tax reform: Guidance issued for non-domiciled individuals
[English] [Simplified Chinese] [Japanese]
Year 2018
P289/2018 - 28 December 2018
New cross-border e-commerce policies announced
[English] [Simplified Chinese] [Japanese]
P288/2018 – 24 December 2018
Individual Income Tax (IIT) reform: New requirements relating to IIT withholding and self-declarations
[English] [Simplified Chinese] [Japanese]
P287/2018 – 24 December 2018
Individual Income Tax Reform: Final implementation regulations for IIT law released
[English] [Simplified Chinese] [Japanese]
P286/2018 – 24 December 2018
Individual Income Tax Reform: Guidance released on additional itemized deductions
[English] [Simplified Chinese] [Japanese]
P285/2018 – 21 December 2018
Individual Income Tax Reform: Guidance released on tax withholding under new IIT law
[English]
P282/2018 – 22 October 2018
Individual Income Tax Reform: Draft implementation regulations released for public consultation
[English] [Simplified Chinese] [Japanese]
P281/2018 – 22 October 2018
Individual Income Tax Reform: Consultation Paper released on additional itemized deductions
[English] [Simplified Chinese] [Japanese]
P278/2018 – 17 September 2018
Aligning China R&D arrangements and transfer pricing in a post BEPS world
[English] [Simplified Chinese] [Japanese]
P277/2018 – 3 September 2018
Individual Income Tax (IIT) Reform: Amended IIT Law approved
[English] [Simplified Chinese] [Japanese]
P276/2018 – 3 August 2018
WCO releases 2018 "Guide to Customs Valuation and Transfer Pricing"
[English] [Simplified Chinese] [Japanese]
P275/2018 – 3 July 2018
Individual Income Tax Reform: Draft amendments released for public consultation
[English] [Simplified Chinese] [Japanese]
P274/2018 – 6 April 2018
Guidance issued on new VAT rate reductions and changes relating to small-scale VAT payers
[English] [Simplified Chinese] [Japanese]
P273/2018 – 8 March 2018
Customs credit management system revised
[English] [Simplified Chinese] [Japanese]
P271/2018 – 23 February 2018
SAT updates guidance on interpretation of tax treaties
[English] [Simplified Chinese] [Japanese]
P270/2018 – 8 February 2018
SAT published new rules on beneficial owners
[English] [Simplified Chinese] [Japanese]
P269/2018 – 17 January 2018
SAT issues guidance on registration of general VAT payers
[English] [Simplified Chinese] [Japanese]
P268/2018 – 10 January 2018
Tariff adjustments for 2018 announced
[English] [Simplified Chinese] [Japanese]
Year 2017
P265/2017 – 27 October 2017
New guidance clarifies rules relating to EIT withholding on China-source income derived by nonresident enterprises
[English] [Simplified Chinese] [Japanese]
P264/2017 – 1 August 2017
China signs MLI to modify tax treaties
[English] [Simplified Chinese] [Japanese]
P263/2017 – 28 July 2017
New VAT guidance issued on industry-specific issues
[English] [Simplified Chinese] [Japanese]
P262/2017 – 3 July 2017
VAT on asset management products postponed
[English] [Simplified Chinese] [Japanese]
P261/2017 – 28 June 2017
SAT strengthens management of VAT general invoices
[English] [Simplified Chinese] [Japanese]
P260/2017 – 1 June 2017
Consequences of reduction in VAT rate bands
[English] [Simplified Chinese] [Japanese]
P259/2017 – 22 May 2017
China CRS rules apply as from 1 July 2017
[English] [Simplified Chinese] [Japanese]
P258/2017 – 31 March 2017
SAT issued new rules to improve administration of special tax investigation and adjustment and mutual agreement procedures
[English] [Simplified Chinese] [Japanese]
P256/2017 – 26 January 2017
Government authorities coordinate to offer joint incentives for customs advance certified
[English] [Simplified Chinese] [Japanese]
P255/2016 – 10 January 2017
SAT clarifies post-VAT reform land appreciation tax issues
[English] [Simplified Chinese] [Japanese]
Year 2016
P254/2016 – 27 December 2016
New VAT guidance addresses industry-specific issues
[English] [Simplified Chinese] [Japanese]
P253/2016 – 13 December 2016
GAC issues 2017 edition of Harmonized System Nomenclature
[English] [Simplified Chinese] [Japanese]
P252/2016 – 22 November 2016
Update on export tax refunds: Revised guidance on administrative classification of export enterprises
[English] [Simplified Chinese] [Japanese]
P251/2016 – 7 November 2016
Chinese customs authorities issue updated guidance on customs audits
[English] [Simplified Chinese] [Japanese]
P250/2016 – 28 October 2016
Comprehensive resource tax reform kicked off in China - Water resource tax piloted in Hebei province
[English] [Simplified Chinese] [Japanese]
P248/2016 – 18 October 2016
SAT issued new rules to improve administration of advance pricing arrangements
[English] [Simplified Chinese] [Japanese]
P247/2016 – 17 October 2016
State Administration of Taxation ("SAT") released draft "Due Diligence Procedures on Financial Account Information in Tax Matters for Non-residents" Are you ready?
[English] [Simplified Chinese]
P245/2016 – 28 September 2016
Favorable tax treatment extended to more equity compensation plans / contributions of technology
[English] [Simplified Chinese]
P244/2016 – 8 September 2016
VAT Reform - SAT clarifies disputed VAT issues
[English] [Simplified Chinese] [Japanese]
P243/2016 – 8 August 2016
Chinese court rules offshore merger by absorption does not qualify for special reorganization relief
[English] [Simplified Chinese] [Japanese]
P242/2016 – 4 August 2016
New China - Germany agreement on the avoidance of double taxation and the prevention of fiscal evasion
[English] [Simplified Chinese]
P241/2016 – 13 July 2016
SAT issued new rules on reporting of related party transactions and contemporaneous documentation
[English] [Simplified Chinese] [Japanese]
P240/2016 – 27 May 2016
VAT Reform – SAT promulgated interim measures related to real estate and construction sectors
[English] [Simplified Chinese] [Japanese]
P238/2016 – 6 April 2016
VAT Reform – SAT promulgated interim measures related to real estate and construction sectors
[English] [Simplified Chinese] [Japanese]
P236/2016 – 2 April 2016
VAT Reform - Construction sector
[English] [Simplified Chinese] [Japanese]
P235/2016 – 30 March 2016
VAT Reform - Lifestyle services sector
[English] [Simplified Chinese] [Japanese]
P234/2016 – 29 March 2016
VAT Reform - Financial services sector
[English] [Simplified Chinese] [Japanese]
P233/2016 – 31 March 2016
VAT Reform - Real estate sector
[English] [Simplified Chinese] [Japanese]
P232/2016 – 24 March 2016
MOF and SAT announced detailed rules for VAT Reform rollout to cover all industries
[English] [Simplified Chinese] [Japanese]
Year 2015
P231/2015 – 16 November 2015
Results of high and new technology enterprise status verification announced
[English] [Simplified Chinese] [Japanese]
P230/2015 – 15 October 2015
BEPS action 7: Preventing the artificial avoidance of PE status
[English] [Simplified Chinese] [Japanese]
P229/2015 – 7 October 2015
Final BEPS reports released: An overall perspective
[English] [Simplified Chinese] [Japanese]
P228/2015 – 22 September 2015
Mainland China and Taiwan sign tax agreement
[English] [Simplified Chinese] [Japanese]
P227/2015 – 21 September 2015
SAT issues new rules for claiming treaty benefits
[English] [Simplified Chinese] [Japanese]
P226/2015 – 21 September 2015
Discussion draft of "Implementation Measures of Special Tax Adjustment" released by the China's State Administration of Taxation
[English] [Simplified Chinese] [Japanese]
P225/2015 – 13 August 2015
China issues regulations on cost sharing agreements
[English] [Simplified Chinese] [Japanese]
P224/2015 – 6 August 2015
Free trade agreement signed with Australia
[English] [Simplified Chinese]
P223/2015 – 27 July 2015
BEPS Actions 8, 9 and 10: Transfer pricing update
[English] [Simplified Chinese] [Japanese]
P222/2015 – 17 July 2015
SAT issues guidance on tax administration of enterprise reorganizations
[English] [Simplified Chinese] [Japanese]
P221/2015 – 15 July 2015
SAT issues new guidance on special tax treatment on intragroup assignment of shares or assets
[English] [Simplified Chinese] [Japanese]
P220/2015 – 14 July 2015
BEPS Action 7: OECD releases revised discussion draft on definition of permanent establishment
[English] [Simplified Chinese] [Japanese]
P219/2015 – 26 June 2015
BEPS Action 13: Country-by-country reporting implementation package
[English] [Simplified Chinese] [Japanese]
P218/2015 – 19 June 2015
BEPS Action 8: OECD issues discussion draft on hard-to-value intangibles
[English] [Simplified Chinese] [Japanese]
P217/2015 – 18 May 2015
Individual income tax treatment of contribution of nonmonetary assets clarified
[English] [Simplified Chinese] [Japanese]
P216/2015 – 13 May 2015
BEPS Action 8: OECD releases draft guidance on cost contribution arrangements
[English] [Simplified Chinese] [Japanese]
P215/2015 – 9 April 2015
SAT releases new bulletin to strengthen Transfer Pricing administration on Intra-group outbound charges
[English] [Simplified Chinese] [Japanese]
P214/2015 – 11 March 2015
China-Korea Free Trade Agreement – One of the most popular potential FTA
[English] [Simplified Chinese]
P213/2015 – 13 February 2015
BEPS Action 13: OECD issues guidance on CbC reporting implementation
[English] [Simplified Chinese] [Japanese]
P212/2015 – 6 February 2015
SAT issues new rules on indirect transfers of assets by nonresident enterprises
[English] [Simplified Chinese] [Japanese]
P211/2015 – 4 February 2015
BEPS Action 10: Discussion draft on the use of profit splits in the context of global value chains
[English] [Simplified Chinese] [Japanese]
P210/2015 – 30 January 2015
BEPS Actions 8, 9, and 10: Discussion draft on revisions to chapter I of the transfer pricing guidelines (including risk, recharacterization, and special measures)
[English] [Simplified Chinese] [Japanese]
P209/2015 – 23 January 2015
BEPS Action 14: Make dispute resolution mechanisms more effective
[English] [Simplified Chinese] [Japanese]
P208/2015 – 21 January 2015
BEPS Action 4: Discussion draft released on deductibility of interest expense
[English] [Simplified Chinese] [Japanese]
P207/2015 – 19 January 2015
BEPS Action 10: Discussion draft on the transfer pricing aspects of cross-border commodity transactions
[English] [Simplified Chinese] [Japanese]
P206/2014 – 16 January 2015
OECD Issues BEPS Transfer Pricing Discussion Drafts
[English] [Simplified Chinese] [Japanese]
Year 2014
P205/2014 – 30 December 2014
SAT issues guidance on tax treatment of share transfers by individuals
[English] [Simplified Chinese] [Japanese]
P204/2014 – 29 December 2014
China tariff policy for 2015 announced
[English] [Simplified Chinese] [Japanese]
P203/2014 – 19 December 2014
SAT issues regulations on the application of the GAAR
[English] [Simplified Chinese] [Japanese]
P202/2014 – 14 November 2014
BEPS Action 10: Proposed modifications to transfer pricing guidelines relating to low value-adding intragroup services
[English] [Simplified Chinese] [Japanese]
P201/2014 – 7 November 2014
BEPS Action 7: Preventing the artificial avoidance of PE status
[English] [Simplified Chinese] [Japanese]
P200/2014 – 15 October 2014
BEPS Action 2: Hybrid mismatch arrangements
[English] [Simplified Chinese] [Japanese]
P199/2014 – 29 September 2014
OECD Release on Intangibles: Many issues unanswered
[English] [Simplified Chinese] [Japanese]
P198/2014 – 29 September 2014
OECD releases the BEPS Project 2014 deliverables
[English] [Simplified Chinese] [Japanese]
P197/2014 – 29 September 2014
OECD Chapter I Release: Important guidance on location-specific advantages and passive association
[English] [Simplified Chinese] [Japanese]
P196/2014 – 26 September 2014
BEPS Action 15: Developing a multilateral instrument to modify bilateral tax treaties
[English] [Simplified Chinese] [Japanese]
P195/2014 – 25 September 2014
BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances
[English] [Simplified Chinese] [Japanese]
P194/2014 – 24 September 2014
OECD Release on Transfer Pricing Documentation: The new global standard
[English] [Simplified Chinese] [Japanese]
P193/2014 – 11 July 2014
Transfer Pricing and ‘High and New Technology Enterprises’ in China: What you need to know
[English] [Simplified Chinese] [Japanese]
P192/2014 – 21 May 2014
BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances
[English] [Simplified Chinese] [Japanese]
P191/2014 – 13 May 2014
BEPS Action 2: Hybrid mismatch arrangements
[English] [Simplified Chinese] [Japanese]
P190/2014 – 12 May 2014
BEPS Action 1: Tax challenges of the digital economy
[English] [Simplified Chinese] [Japanese]
P189/2014 - 29 January 2014
New China-UK tax treaty enters into force
[English] [Simplified Chinese] [Japanese]
Year 2013
P188/2013 - 19 December 2013
MOF and SAT issue new VAT reform rules
[English] [Simplified Chinese] [Japanese]
P187/2013 - 9 October 2013
SAT issues guidance on application of VAT exemption treatment
[English] [Simplified Chinese] [Japanese]
P186/2013 - 27 September 2013
China (Shanghai) Pilot Free Trade Zone: Open for Business
[English] [Simplified Chinese] [Japanese]
P185/2013 - 6 September 2013
SAT issues guidance on application of zero-rated VAT treatment
[English] [Simplified Chinese] [Japanese]
P184/2013 - 26 July 2013
China relaxes foreign exchange procedures on outbound payments for trade in services
[English] [Simplified Chinese] [Japanese]
P183/2013 - 3 June 2013
MOF and SAT issue new regulations on nationwide implementation of VAT reform on transportation and modern services sectors
[English] [Simplified Chinese] [Japanese]
P182/2013 - 27 May 2013
New Guidance Clarifies IIT Treatment of POst-Acquitsition Capitalization of Undistributed Profits or Reserves
[English] [Simplified Chinese]
P181/2013 - 17 May 2013
SAT clarifies when a secondment arrangement creates a PE
[English] [Simplified Chinese] [Japanese]
P180/2013 - 8 May 2013
SAT issues guidance on beneficial ownership of dividends under tax arrangement with Hong Kong
[English] [Simplified Chinese] [Japanese]
P179/2013 - 4 February 2013
SAT further clarifies EIT filing requirements for enterprises with branches
[English] [Simplified Chinese] [Japanese]
P178/2013 - 24 January 2013
SAT updates guidance on application of capital gains article in China’s tax treaties
[English] [Simplified Chinese] [Japanese]
P177/2013 –17 January 2013
SAFE simplifies rules on administration of foreign exchange for direct investment
[English] [Simplified Chinese] [Japanese]