Macau SAR

There is no provision for group taxation in Macau SAR.

Transfer pricing (TP)

TP became effective on 1 January 2026, and TP Implementation Regulation has been published in the form of an administrative regulation to facilitate the implementation of the TP rules. The key TP measures and the respective effective dates are as follows:

The TP regulatory regime 

The Tax Code stipulates that in cases where a Macau taxpayer or its related parties do not comply with the arm’s length principle, the MFB may use transfer pricing methods (i.e. comparable uncontrolled price method, resale price method, cost-plus method, profit split method, transactional net margin method, or other TP methodologies that better reflect the alignment of profits against the location of economic activities and value creation) to make indirect assessments and tax adjustments.

Additionally, if the competent authority of the related party’s tax jurisdiction adjusts the assessable profits of the related party, the MFB may make corresponding adjustments in accordance with the provisions of the tax treaty signed between the Macau SAR and the tax jurisdiction concerned.

Disclosure of controlled transactions and TP documentation

The TP rules require taxpayers to prepare all TP material documents within nine months after the end of each fiscal year and to retain these documents for seven years after the end of the relevant fiscal year. The filing requirements for master files, local files, country-by-country reporting and controlled transactions summary are as follows:

• Master file: If the total annual amount of controlled transactions in a fiscal year exceeds MOP 1 billion, or if the taxpayer engages in cross-border controlled transactions and the ultimate parent company of that taxpayer's consolidated group has prepared a master file, the taxpayer must maintain a master file in accordance with Article 3, Paragraph 2(1) of Administrative Regulation No. 1/2020, including information on the group’s organisational structure, business operations, intangible assets, financial activities between constituent entities, financial position and tax position.
• Local file: If any of the following circumstances occur in the annual amount of controlled transactions during the year, taxpayers must prepare a local file in accordance with Article 3, Paragraph 2(2) of Administrative Regulation No. 1/2020: (a) transfer of ownership of tangible assets exceeds MOP 200 million; (b) transfer of ownership of financial assets exceeds MOP 100 million; (c) transfer of ownership of intangibles exceeds MOP 100 million; or (d) aggregated amount of other controlled transactions exceeds MOP 40 million. The above amounts do not include the transactions covered under a concluded APA. Taxpayers who have signed an APA are exempted from preparing local file for the controlled transactions covered in the APA.
• Country-by-country (CbC) reporting: Qualified multinational enterprise groups shall prepare CbC information on the group’s revenue, profit before income tax, tax paid and accrued, and other specific indicators in each tax jurisdiction where the group has business operations in accordance with Article 3, Paragraph 2(3) of Administrative Regulation No. 1/2020.
• Controlled transactions summary: When the total annual amount of controlled transactions in a fiscal year reaches MOP 10 million, taxpayers must submit a summary form in the Complementary Tax Return for Group A taxpayers to disclose its controlled transactions in the fiscal year, stating the names, tax jurisdictions and tax identification numbers of the related parties, as well as the types of controlled transactions and respective amounts.

If documents submitted by the taxpayer are not prepared in any of the official languages of Macau SAR (i.e. Chinese and Portuguese), a translation must be attached. However, the MFB has discretion to exempt a translation if it considers it practical to comprehend the content written in the original language.

The advance pricing arrangement (APA) regime

If the annual amount of controlled transactions is MOP 40 million or above, Macau taxpayers can sign a unilateral APA with the MFB regarding the commercial or financial transactions between related parties, to determine the arm’s length pricing policy and calculation method for these transactions conducted within a specified period. The Implementation Regulation clarifies that the APA shall cover no more than five years including the covered years of assessment. As long as the facts and circumstances are consistent with or similar to those specified in the APA, it is also possible to apply for a rollback i.e. retrospective adjustment for up to two years of assessment prior to the signing date, provided that the tax assessments regarding the controlled transactions in the relevant retrospective years have not been concluded.

Thin capitalisation

There is no thin capitalisation provision in the Macau tax regime.

Controlled foreign companies (CFCs)

There are no CFC rules in the Macau tax regime.