State Taxation Administration Bulletin 16 Transfer Pricing Audit Defense Mechanics
Bulletin 16 audit defense requires proving direct economic benefit, foreign DEMPE contributions, and arm's length pricing through verifiable contemporaneous dossiers.
Bulletin 16 audit defense requires proving direct economic benefit, foreign DEMPE contributions, and arm's length pricing through verifiable contemporaneous dossiers.

Resolving intercompany IP disputes in MAP negotiations requires matching DEMPE economic evidence to bilateral valuation models to eliminate double taxation.

Resolving Chinese tax audits on service establishments requires proving actual arm's-length profits or negotiating defensible deemed profit rates under Announcement 2010 No. 19.
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