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State Administration of Taxation Issued Announcement on the Enhancement of Administration of APA

SAT on the Enhancement of Administration of APA

China Tax Alert - Issue 28, October 2016

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China Tax Alert

On 18 October 2016 an State Administration of Taxation (SAT) Announcement on the Enhancement of Administration of Advance Pricing Arrangement (APA) (“Announcement 64”) was published on a public information platform. Announcement 64 replaces the current relevant regulations on APA administration as prescribed under Chapter 6 of the Implementation Measures for Special Tax Adjustments (Trial Implementation), Guoshuifa [2009] No.2 (“Circular 2”). It will come into effect beginning on 1 December 2016 and be applicable to APA applications that are not yet formally accepted by the tax authority before the announcement’s implementation.

Since the SAT released Circular 2’s revised version, Public Consultation Draft of Implementation Measures for Special Tax Adjustments (“Discussion Draft”), in September 2015, finance and tax professionals and entrepreneurs have been expecting significant revisions to the regulations for special tax adjustments. After the SAT issued the Announcement on the Enhancement of the Reporting of Related Party Transactions and Administration of Contemporaneous Documentation (“Announcement 42”) in June 2016, making the first step to localise Base Erosion and Profit Shifting (BEPS) action plans, we now finally witness the arrival of the updated APA administration requirements.

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© 2022 KPMG Huazhen LLP, a People's Republic of China partnership, KPMG Advisory (China) Limited, a limited liability company in Mainland China, KPMG, a Macau (SAR) partnership, and KPMG, a Hong Kong (SAR) partnership, are member firms of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organisation.

For more detail about the structure of the KPMG global organisation please visit https://home.kpmg/governance.

京ICP备12028186号-1
京公网安备11010102003233号

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