Transfer Pricing Viewpoint: Issue 3
21 March 2011
In this issue of Viewpoint, experts from NERA's Global Transfer Pricing Practice examine trends and implications of recent transfer pricing developments from an economic perspective. The authors provide an overview of new documentation requirements in Japan, which include two types of documents, one describing intercompany transactions and the other for arm's length tests. They also discuss the recent release of China's Advance Pricing Agreement (APA) report, the first such report since the introduction of China's APA program in 1998. The report, which includes data and analysis of APA cases in the period from 2005-2009, emphasizes the importance of an effective APA program in the anti-avoidance administration in China.
