German Business Wants China Transfer Pricing Path Reopened

May 1, 2026, 8:45 AM UTC

German multinationals are holding out hope that tax officials and China’s government can break an impasse over cross-border transfer pricing arrangements as the countries restart negotiations over a path to more tax certainty.

Germany’s Federal Central Tax Office has reentered negotiations with Chinese authorities on advance pricing agreements, according to a person familiar with the matter, after the office said last July that it wouldn’t agree to further APAs or renew existing ones with China.

The July news was a blow, German tax practitioners said, because it had potential to exacerbate economic tensions with the country’s biggest ...

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