Transfer pricing (转让定价)

Chinese:transfer pricingAlso known as:related-party pricing / intercompany pricing / internal pricing

Transfer pricing is the pricing of transactions between associated enterprises, such as sales of goods, services, asset transfers and financing. Tax law requires these prices to follow the arm’s length principle; where they do not and taxable income is reduced, the tax authority may make a special tax adjustment.

Key points

  • The core principle is the arm’s length principle: prices between related parties should match those agreed between unrelated parties under the same or similar conditions.
  • Common methods: comparable uncontrolled price (CUP), resale price method (RPM), cost plus method (CPLM), transactional net margin method (TNMM) and profit split method (PSM).
  • Cross-border related-party transactions are also affected by rules arising from the OECD/G20 Base Erosion and Profit Shifting (BEPS) Action Plan, under which many countries have strengthened documentation and disclosure requirements.

In practice

In a group trade chain, transfer pricing decides which entity keeps the profit and in which tax jurisdiction it is taxed. A common approach is to set a pricing rule for each type of internal transaction – for example an external comparable price plus or minus a fixed fee, or a reasonable gross margin range retained by the distribution entity, with the remaining profit going to the entity that bears the principal risks.

The hard part is consistent execution. The rules are written into policy documents, but whether each internal price was actually generated by the rule, how far it deviated and whether each entity’s full-year margin falls within the target range are often only known at year end. Good practice is to calculate internal prices by rule, with a record, at the moment each transaction takes place, monitor each entity’s margin regularly, and build up the data for contemporaneous documentation.

How Tranexio supports it

Within a trade chain, Tranexio allocates profit to each entity according to configured transfer pricing rules (CUP, RPM, cost plus, TNMM, PSM), records each internal transaction price and its basis, and provides a BEPS compliance self-check. See Trade chain management and transfer pricing.

Frequently asked questions

What are the common transfer pricing methods?

Methods recognised under Chinese tax law are the comparable uncontrolled price method, the resale price method, the cost plus method, the transactional net margin method, the profit split method, and other methods consistent with the arm’s length principle. Trading companies buying and selling goods most often use the comparable uncontrolled price or resale price method.

What is contemporaneous documentation?

Contemporaneous documentation is the set of documents a company prepares, as required by regulation, to show that its related-party pricing is reasonable. It comprises the master file, the local file and the special issue file. Companies that meet the prescribed thresholds must prepare it on time and provide it when the tax authority requests it.

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Updated 2026-10-06