近三年来，海关将进口货物审价的重点转向了特殊关系影响成交价格的审查，特别存在转让定价安排的龙头跨国企业是海关审查的重要对象。由于海关往往倾向于认定企业整体利润率过高是因为进口价格过低导致，需要调高进口价格补税；而税务机关恰恰相反，倾向于防止利润率过低侵蚀所得税税基。现有海关和税务机关各自的价格预裁定和预约价格安排机制虽可在一定程度上提高企业对执法的预见性，但是由于缺乏协调机制，在两部门相互冲突的税收目标下，跨国企业制定转让定价安排仍然面临不确定的税务负担和冲突的审查标准。而且，实践中海关很少对价格作出预裁定，预裁定更多被应用于归类领域。

2022年5月18日，深圳海关和国家税务总局、深圳市税务局联合发布了《关于实施关联进口货物转让定价协同管理有关事项的通告》（深关税〔2022〕62号）旨在解决这一问题。据悉，本次协同管理系在海关总署和国家税务总局共同指导下形成的全国首例海关、税务转让定价协同管理的方案（简称“本次方案”），很可能对其他地方的海关和税务机关形成示范、推广效应，非常值得存在转让定价安排的关联进口企业，特别跨国企业的关注。为此，欧盟商会南京分会特邀德勤海关、税务专家结合过往应对海关转让定价审查的经验对本次方案中的重点内容做出分析、解读，供相关企业参考。

In the past 3 years, due to the lack of coordination mechanism, transnational enterprises still face uncertain tax burden and conflicting examination standards when making transfer pricing arrangements under the conflicting tax objectives of the Customs and the Taxation Bureau. Moreover, in practice, the customs seldom makes a preliminary ruling on the price, and the preliminary ruling is more used in the field of classification.

On May 18, 2022, Shenzhen Customs, the State Administration of Taxation and Shenzhen Municipal Taxation Bureau jointly issued the Notice on Matters Related to the Implementation of the Coordinated Management of Transfer Pricing of Related Import Goods (Shenzhen Tariff [2022] 62) to address this problem. It is reported that this coordinated management is the first coordinated management scheme of Customs and tax transfer pricing in China under the guidance of the General Administration of Customs and the State Administration of Taxation (referred to as "this scheme"), which is likely to have a demonstration and promotion effect on customs and tax authorities in other places, and is very worthy of the attention of related import enterprises with transfer pricing arrangements, especially multinational enterprises. Therefore, the European Chamber Nanjing invited the experts from Deloitte to review the customs transfer pricing and interpret the key content of this program combining with the past experience.

• 2023-06-20 | 15:00 - 16:30
• Deloitte Nanjing Office

The Finance and Taxation Working Group invites members to participate in the government meeting with Shenzhen Municipal Office, State Administration of Taxation (SAT).

• 2017-11-24 | 10:30 - 12:00
• Courtesy of Exertis圣路兴商贸（深圳）有限公司

The tax environment in China is one of the most complex and challenging tax environments in the world. Frequent regulatory changes, inconsistent interpretation and practices, an aggressive tax audit environment, and lack of effective appeal in China have led to inevitable uncertainties and challenges for our taxpayers and EU companies in China.

• 2017-11-23 | 09:00 - 11:00
• European Chamber Shanghai Office

China Customs published a series of compliance requirements for importers and exporters. With the ongoing reform of customs clearance processes and national integration Customs is dedicating more resources to risk management and post-clearance investigation, such as the national audit on royalties.

• 2017-09-19 | 14:30 - 17:30
• Courtesy of KPMG China, Training room 1&2, 22nd Floor, CTF Finance Center

China Customs published a series of compliance requirements for importers and exporters. With the ongoing reform of customs clearance processes and national integration Customs is dedicating more resources to risk management and post-clearance investigation, such as the national audit on royalties.

• 2017-09-18 | 14:30 - 17:30
• Courtesy of Exertis Supply Chain Service, 19/F AB, Tower A, Honglong Century Plaza

The European Chamber of Commerce in South China and Fiducia Management Consultants are pleased to invite you to the upcoming Finance ad taxation Working Group meeting focusing on recognizing and mitigating the risk of fraud.

• 2017-09-05 | 14:30 - 17:30
• Langham Shenzhen, 4th Floor, Soho Room

The European Chamber is glad to invite you to a seminar that will analyse the recent changes to customs reporting on price and royalty in China. It will take place on Wednesday, 30th August, 9:00-11:00 in the European Chamber Shanghai office.

With the changes introduced in customs declarations, customs valuations and dutiable royalties by GAC Announcement [2016] No. 20 and GAC Announcement [2017] No. 13, the European Chamber has invited experts from Deloitte and Sandler, Travis & Rosenberg, Ltd to share major revision, cases and best practice for the enterprises to cope with the changes.

• 2017-08-30 | 09:00 - 11:00
• European Chamber Shanghai Office, Unit 2204

The European Chamber is glad to invite you to a dialogue on the new Environmental Protection Tax that will take place on Thursday, 15th June, 9:00-11:00 in the European Chamber Shanghai office.

The Environmental Protection Tax Law is already here, and will have a perdurable effect on your business. During this event, you will discover the new tax’s impact on the activities of your company and its numerous and formidable consequences, through an insightful and dynamic dialogue between our three experts and the audience.

• 2017-06-15 | 09:00 - 11:00
• European Chamber Shanghai Office, Unit 2204

This seminar will introduce the latest transfer pricing developments and trends in China in the wake of BEPS and the recent (draft) China Chapter of the new version of the United Nations Transfer Pricing Manual for developing countries as well as the recent Bulletin 6, third and final bulletin in a series through which the State Administration of Taxation (SAT) has comprehensively revised the transfer pricing regime under the former Circular 2. Bulletin No. 6 key provisions and their implications for multinational companies (MNCs) will be analysed.

• 2017-05-10 | 09:00 - 11:00
• European Chamber Shanghai Office, Unit 2204

On 25 December 2016, the Standing Committee of China’s National People’s Congress adopted China’s first Environmental Protection Tax Law (the Law). The Law is poised to replace the existing pollutant discharge fee system with a pollution tax as the main economic tool regulating environmental pollution by businesses in China. This historic development is expected to have sweeping impacts on enterprises’ compliance with China’s environmental regulations.

• 2017-04-07 | 10:00 - 11:30
• Guangdong Local Taxation Bureau