How it works in practice
Start with a functional analysis (who does what, who bears risk, who owns intangibles), then test pricing methods and documentation readiness before year-end. Dividend planning, management fees, and R&D cost shares often need joint tax and legal review. See also profit repatriation and SAFE explainers when cash leaves China.
FAQ
Is a simple cost-plus always safe?
No. The method must fit the functions and risks. Cost-plus can be wrong for unique intangibles or limited-risk assumptions that do not match reality.
Do small FIEs escape TP rules?
Documentation thresholds may ease burden, but arm’s-length principles and related-party disclosure can still apply. Size is not a free pass.