Nowadays, transfer pricing has become the key point of tax audit. That keeping and supplying contemporaneous documentation is general obligation of enterprises indicates the much attention which tax authorities pay on the supervision and investigation for internal trade in groups. The declaration of related-party transaction and the formulation of transfer pricing materials expose the secret relations between enterprise groups themselves, especially transnational enterprises and the enterprises existing special consideration. The ratio of commercial factors to non-commercial considerations in transfer pricing becomes the key point to reflect the essence of trades. The requirement that ex post materials and proofs must concentrate on ex-ante transfer pricing policies urges enterprises to observe the principles of reasonable business and independent operation, rationalize the relationship between legal persons, establish rational commercial pricing system and management system, guarantee the compliance of transfer pricing and prevent the risk of anti-tax-avoidance when adjusting internal relationships.
Colleagues of Hwuason Law Firm can cooperate with enterprises to rationalize and adjust the relationships between internal enterprise groups and between subjects, establish structure mode corresponding to commercial benefits, as well as document the production relationship, sales relationship and flow of operation, make design files corresponding to trade essence and related regulations.

• Suggestions of optimizing internal structure
• Schemes of adjusting enterprises’ operation flow
• Schemes of transfer pricing and essential control
• Cooperating to carry out the internal adjustment
• Risk assessment and report
• The administration and policy setting of transfer pricing
• Signing internal files and contracts
• Subsequent follow-up and annual update