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The Evolving Transfer Pricing Landscape in China — Challenges for High-Tech Companies in China

The Chinese Government has set the structural transformation of the Chinese economy as one of its national priorities.2 As part of that endeavour, China wants to move away from being a manufacturing hub to one that occupies multiple and more value-added functions in the global supply chain. To that end, it is focusing on research and development (R&D), high-end manufacturing, and service sector development. This direction presents a unique opportunity to companies in the high-tech industry. Since 2008, most tax incentives have been directed at companies with advanced technology. On the other hand, this has also made these companies more visible to the Chinese authorities, including the transfer pricing authorities.