In accordance with Notice of the State Administration of Taxation on Issuing the Measures for the Implementation of Special Tax Adjustments (for Trial Implementation), qualified enterprises shall prepare the annual contemporaneous documentation before May 31st of the following year after related party transactions occurred. Meanwhile, No. 363[2009] ...More

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 ...More

With the influence of global economic situation, investigation into transfer pricing has been strengthened constantly all over the world. More than 60 countries and religions in the world have already put forward relevant provisions about transfer pricing until 2009. Chinese tax authority put forward a series of transfer pricing managerial system i ...More

Advance Pricing Arrangements An Advance Pricing Arrangements (APA) is an advance agreement between the taxpayer and the authorities as to the appropriate pricing methodology to be utilized by the taxpayer. Chinas transfer pricing rules allow for APAs. APAs enable taxpayers to greatly reduce their transfer pricing risk and the threat of future chall ...More

In accordance with the Enterprise Income Tax Law of the Peoples Republic of China and the Regulation on the Implementation, enterprises can reach the cost contribution arrangements conforming to arms length principle for sharing the common cost with their affiliates. The cost contribution arrangements (CCA) is reached by enterprises in order to sha ...More