Macau SAR Publishes Implementation Rules For Transfer Pricing Administration

Summary

The Macau Special Administrative Region of the People's Republic of China ("Macau SAR") government officially issued the "Implementation Rules for Transfer Pricing" (Administrative Regulation No. 11/2025) on August 25, 2025 (hereinafter referred to as "the Implementation Rules"). The rules further refine Macau SAR's transfer pricing regulations, aiming to improve transparency and align local tax laws with international anti-tax avoidance standards. The Implementation Rules directly affect transfer pricing arrangements between Macau SAR taxpayers and their related parties. They took effect on 1 January 2026 and apply to all controlled related-party transactions from that date.