SAT Issued New Rules to Improve Administration of Advance Pricing Arrangements

Tax Analysis:November 2016/China

On 11 October 2016, China’s State Administration of Taxation (SAT) issued new regulations (Bulletin 64) to improve the administration of Advance Pricing Arrangements (APAs). (Tax Analysis:November 2016/China)

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Bulletin 64 is released as the second significant revision, following the previous issuance of SAT Bulletin [2016] No. 42 (Bulletin 42) in June 2016 on reporting of related party transactions and contemporaneous documentation, to the relevant chapters of the Implementing Measures for Special Tax Adjustments (for Trial Implementation) (SAT Circular Guoshuifa [2009] No. 2 or “Circular 2”) and become another important rules of Chinese special tax adjustment. Bulletin 64 will apply from 1 December 2016 and the applicable sections concerning APAs in the old regulations (i.e. Chapter 6 of Circular 2) will be repealed.

This newsletter explains the following topics;

(1) Changes and key points in APA applications
(2) Tax authorities involved in APA procedures
(3) Changes and key points in APA process
(4) Covered period and roll-back of APA
(5) Information exchange for unilateral APAs
(6) Miscellaneous
(7) Deloitte’s observation


>> Click for Japanese [中国国家税務総局が事前確認管理の規範化に関する公告を公布]

(157KB, PDF)

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