Macau SAR publishes Implementation Rules for Transfer Pricing administration

On December 16, 2024, the Macau SAR government introduced a transfer pricing regime through the passage of the “Approval of the Tax Code” bill (hereinafter referred to as “the Tax Code”), clarifying the concept of transfer pricing and the principle of related-party transactions, and requiring that transactions between taxpayers in Macau SAR and their related parties in other tax jurisdictions should comply with the arm’s length principle.

To implement the provisions on transfer pricing in the Tax Code and the Supplementary Tax Regulations, the Macau SAR government published the Implementation Rules in the form of an administrative regulation on August 25, 2025. These rules provide detailed and specific guidelines on the application of the arm’s length principle, methods for transfer pricing adjustments, requirements for the retention of controlled transaction documentation (i.e., transfer pricing compliance documents), and Advance Pricing Arrangement (hereinafter referred to as “APA”). The issuance of the Implementation Rules is significant for guiding the Macau SAR Finance Bureau and taxpayers in implementing transfer pricing administration, including compliance reporting of related party transactions, application of transfer pricing methods, assessment and adjustment of controlled transactions, and the application, negotiation and supervision over APAs.