In September 2013, China’s State Administration of Taxation and the U.S. Internal Revenue Service reached an agreement in principle on their third bilateral advance pricing arrangement. China and the United States concluded their second bilateral APA in November 2012. The first U.S. – China APA was completed in January 2007.
Detailed procedures for applying for an APA in China are contained in a 2009 document entitled Implementation Measures of Special Tax Adjustments. According to China’s APA report for 2012, issued in June 2013, a total of 85 APAs have been concluded by China up to the end of 2012, including some renewals of existing APAs. This total includes 56 unilateral APAs and 29 bilateral APAs. No multilateral APAs had been concluded by China up to the end of 2012.
