21 October 2016

China's SAT issues new guidance on administration of advance pricing agreements

China's State Administration of Taxation (SAT) issued SAT Bulletin Gonggao [2016] No. 64 (Bulletin on Issues Related to Improving the Administration of Advance Pricing Arrangements) (Bulletin 64) on October 18. Effective from December 1, Bulletin 64 governs the administration of advance pricing agreements (APAs) in China. Bulletin 64 supersedes and replaces Chapter 6 of Circular Guoshuifa [2009] No. 2 (Implementation Measures for Special Tax Adjustments (Trial Implementation)) (Circular 2). An APA is an agreement between a taxpayer and one or more tax authorities regarding how transfer prices will be calculated in the future.

A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2016-1798

Document ID: 2016-1798