SAT solicits public comments on new China transfer pricing and special tax adjustments guidance discussion draft

SAT solicits public comments on new China transfe...

China Tax Alert - Issue 25, September 2015   On 17 September 2015 the State Administration of Taxation (SAT) released the long-awaited public discussion draft of its guidance concerning the implementation of ‘Special Tax Adjustments’ for public consultation. The finalization of the Discussion Draft, anticipated by the end of 2015, would replace the existing SAT guidance on Special Tax Adjustments in Circular 2 [2009], which provides guidance on the Chinese Transfer Pricing (TP) rules and the key Chinese tax law anti-avoidance rules. This document focuses on the changes that we consider will be, in practice, of most significant impact for multinational enterprises.