On 18 May 2022, the city of Shenzhen in the Guangdong Province of Mainland China announced a collaboration between Shenzhen’s customs and tax authorities on transfer pricing administration. The program, which became effective upon announcement, allows qualifying businesses in Shenzhen to have their transfer pricing arrangements for the importation of goods from related parties agreed to by both Shenzhen customs and tax authorities.

It has long been difficult for multinational groups to manage their transfer pricing on related party imports from both customs and income tax perspectives. The customs authorities normally are concerned as to whether the import price declared by an importer is lower than the arm's length range, which would result in lower customs duty and other import taxes. On the contrary, the tax authorities normally are concerned as to whether such import price is higher than the arm's length range, which would erode the taxable profits of the importer. The lack of coordination between the customs and tax authorities makes it cumbersome for businesses to obtain agreement from both authorities simultaneously on such import prices. The launch of the Shenzhen program marks the first time for the customs and tax authorities in China to formally collaborate on transfer pricing administration to address this lack of coordination.

The Shenzhen program essentially consolidates two existing procedures, i.e., advance rulings on customs pricing and advance pricing arrangements (APAs). A qualifying business that participates in the program must meet the requirements of both procedures.

How we can help

Deloitte’s Global Trade Advisory specialists are part of a global network of professionals who can provide specialized assistance to companies in global trade matters. Our professionals can help companies seeking to manage the impacts and potential impacts of the developments described above by:

• Obtaining and analyzing import data to assess the potential impacts of the trade measures;
• Scrutinizing the accuracy of tariff classifications; and
• Planning changes to the supply chain.