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Milestone bilateral advance pricing arrangement for intangible asset transaction reached between the Chinese mainland and Hong Kong
In April 2024, the State Taxation Administration of China and the Inland Revenue Department of the Hong Kong Special Administrative Region reached a consensus and completed the final signing on a bilateral advance pricing arrangement (BAPA). The BAPA covers the transfer pricing arrangement for an intangible asset licensing transaction between a Chinese mainland entity and a Hong Kong entity within a multinational high-end consumer goods group, providing great certainty to the taxpayers’ transfer pricing arrangement.