SAT Issued New Rules to Improve Administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures
Tax Analysis:April 2017/China
On 17 March 2017, the State Administration of Taxation (SAT) issued new regulations to improve administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures (i.e. Bulletin 6, or Bulletin). (Tax Analysis:April 2017/China)
These regulations largely complete the revision of the transfer pricing specific clauses of Circular 2, and add to the transfer pricing framework set out in the previously issued Bulletin 421 and Bulletin 642.
The Bulletin comes into effect from 1 May 2017, and the corresponding sections of previous regulations are repealed3.
1 See Deloitte Tax Analysis on Bulletin 42 (PDF)
2 See Deloitte Tax Analysis on Bulletin 64 (PDF)
3 In addition to corresponding sections in Circular 2, a few other regulations are repealed: Guoshuihan  No. 188, Guoshuihan  No. 363 (Circular 363), SAT Bulletin  No. 54 and SAT Bulletin  No. 16 (Bulletin 16).
This newsletter explains the following topics;
(1) Monitoring of profit level
(2) Special tax audits and adjustments
(3) Corresponding adjustments and mutual agreement procedure
(4) Deloitte’s observation