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Wire · regulatory

China's Transfer Pricing Market Premium May Now Be a Discount

26 October 2026 · By · Wire by Fusion42

Published

26 October 2026

Topic

regulatory

◆ Geography

China

◆ Source

Read at news.bloombergtax.com →

◆ Verified

Fusion42 · 26 October 2026 · Fusion42 review

A new Dentons study challenges China's historical transfer pricing market premium by showing that many multinationals now earn lower profits in China due to rising domestic competition and changing market conditions, suggesting a possible market discount. This is supported by China's UN Transfer Pricing Manual position recognizing market premiums but now potentially justifying discounts where markets have declined.

◆ ◆ The Wire takeaway

Multinationals with declining profits in China must revisit intercompany pricing to claim market discounts under evolving Chinese tax guidelines. You have a chance to renegotiate longstanding agreements that may currently overstate Chinese subsidiary margins.

◆ Coverage

1 source · 26 Oct 2026

◆ Related on Wire

◆ Topics

transfer-pricingchina-marketmultinational-enterprisestax-regulationmarket-premium