Identification of the entity's related parties, documentation of the transactions between them, and the annual declaration that accompanies its corporate income tax return.
What this covers
- The entity's related parties identified through its ownership and control chain, with each relationship's transaction categories mapped
- Intercompany arrangements — service fees, royalties, financing, and goods flows — reviewed against the documentation they will have to support
- An assessment of whether the entity's transaction volumes bring it within the contemporaneous documentation thresholds
- Contemporaneous documentation prepared or reviewed to the standard the applicable threshold requires
- The annual related-party transaction declaration prepared for filing alongside the corporate income tax return
- Coordination with the group's own transfer pricing advisors where pricing policy is set at group level
Our services
Identifying what counts as relatedManagement fees, brand licences, intercompany financing and affiliate trade all qualify — the mapping comes before the documentation.
For a foreign-owned entity, nearly every significant counterparty is a related party. The management fee paid upstream, the licence for the group's brand, the intercompany loan that funded working capital, the goods bought from an affiliate — each is a related-party transaction, each has to be identified as one, and the annual declaration reporting them accompanies the corporate income tax return whether or not anyone prepared for it.
Why a preferential rate raises the barAn entity claiming a reduced rate has an obvious reason for profit to land in it, so its pricing has to be explicable on its own terms.
This matters more in Hainan than it would elsewhere in China, for a reason worth stating plainly: an entity claiming a preferential rate is an entity with an obvious incentive to have profit land in it. That does not make intercompany pricing improper, but it does mean the pricing has to be explicable on its own terms — and documentation assembled after a question is asked reads very differently from documentation that existed before it.
Documentation and the annual declarationContemporaneous documentation where the thresholds bite, and the declaration prepared on the same calendar as the return it accompanies.
We identify the related-party relationships, review the arrangements against the documentation they need to support, and prepare or review the contemporaneous documentation where the entity's volumes reach the applicable threshold. The declaration itself is prepared for filing with the annual return, on the same calendar as the rest of this practice area's work rather than as a separate year-end exercise.
为什么选择 HainanInc？
Documentation prepared as transactions happen, not reconstructed at year end
The declaration tracked on the same calendar as the return it accompanies
Reviewed before submission, not forwarded unread
Related insights
Four Thresholds Decide Whether You Owe Transfer Pricing Documentation
The local file thresholds are specific numbers, tested per category, per year. Below them there is no preparation obligation. Above any one of them, the document is due by 30 June whether or not anyone asks for it.
Economic Substance Requirements in Practice: A Framework for Compliance
Economic substance is no longer a theoretical compliance concept for Hainan-based entities — it is an active area of regulatory review. We outline a practical framework for demonstrating it.
Accounting and Tax全部服务
- Transactional Accountancy Services
- Statutory Accounting and Tax Compliance
- Accounting and Tax Consultancy Services
- Related-Party Transactions and Transfer Pricing
我们的服务
我们的业务领域覆盖外资企业在海南从设立到退出的完整生命周期——从落笔前的可行性评估，到主体设立与牌照申请、薪酬发放、税务与日常合规，再到规范有序的注销清算；同时涵盖自由贸易港各项优惠政策，这正是选择海南而非中国其他地区的理由。统一的服务模式意味着全程由一个团队负责到底。
