In December 2024, the State Taxation Administration of China released the China Advance Pricing Arrangement Annual Report (2023) in both Chinese and English. This marks the 15th time China has released an annual report on Advance Pricing Arrangements (hereinafter referred to as APAs). The report introduces the procedures for the implementation of APAs in China and the progress of related work, covering statistical data and analysis of APA negotiations from 2005 to 2023. The number of APAs signed in China continues to rise. Up until the end of 2023, 153 unilateral APAs and 143 bilateral APAs have been signed in total. An APA refers to an agreement reached by the tax authorities in accordance with the arm's length principle, based on the application submitted by an enterprise regarding the pricing principles and calculation methods for its related party transactions in future years. It is a service provided by the tax authorities to enterprises. As an important measure to optimize the tax business environment, China's APA program is dedicated to providing tax certainty for cross-border taxpayers, with a view to avoiding and eliminating international double taxation. Taxpayers who wish to apply for APAs in China as well as the wider public could both benefit from the report which does not only contain information on the relevant policy and rules but also the latest statistics. The report does not have any legal force and should not be used as the basis for enterprises and Chinese tax authorities to negotiate and sign APAs.

 

Annex: China Advance Pricing Arrangement Annual Report (2023)