Discussion draft of "Implementation Measures of Special Tax Adjustment" released by the China's State Administration of Taxation

Tax Analysis:September 21, 2015/China

China's State Administration of Taxation (SAT) released a discussion draft of "Special Tax Adjustment Implementation Measures" (Draft) on 17 September 2015 that would comprehensively revise existing guidance in this area which had been provided in the existing "Implementation Measures of Special Tax Adjustment (Trial)" (Guoshuifa [2009] No.2, or Circular 2). Circular 2, issued in 2009, is China’s main transfer pricing guidance that contains detailed rules in areas such as transfer pricing adjustments, cost sharing arrangements (CSAs), thin capitalization, etc. (Tax Analysis:September 21, 2015/China)

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The Draft also incorporates a number of recommendations of the OECD in the context of the base erosion and profit shifting (BEPS) initiative, but does so taking into account China’s unique economic environment and factors relevant to the revamping of Circular 2.

This newsletter explains following topics;

  1. Summary of Key Points
  2. Details of the Draft

>> Click for Japanese [中国国家税務総局が「特別納税調整実施弁法」のディスカッションドラフトを公表]

(141KB, PDF)

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