The State Administration of Taxation (SAT) has issued the Internal Working Guidelines for Special Tax Adjustments (Trial) (Guo Shui Fa [2012] No. 13) and Working Guidelines for Re-Examination of Major Cases in Special Tax Adjustments (Trial) (Guo Shui Fa [2012] No. 16), which provide guidance for the tax authorities nationwide on handling all types of special tax adjustment cases, including transfer pricing, advance price arrangements, cost sharing arrangements, controlled foreign corporations, thin capitalisation and general anti-avoidance under Chapter 6 of the Enterprise Income Tax Law. The two sets of guidelines came into effect on 1 March.
The full texts of the two guidelines have not been officially released to the public, as they are internal working guidelines for tax bureaus.
It is worth noting that Notice 13 requires all special tax adjustment cases to be reported to the SAT, which must approve the initiation of the case and any final tax adjustments. This reporting process will help to unify the treatment of special tax adjustment cases nationwide.
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Business Law Digest is compiled with the assistance of Baker & McKenzie. Readers should not act on this information without seeking professional legal advice. You can contact Zhang Danian (Shanghai) at Baker & McKenzie by e-mail at: danian.zhang@bakermckenzie.com
