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ARTICLE · 26 JANUARY 2009

China´s New Transfer Pricing Implementation Rules

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On January 8, 2009, the State Administration of Taxation ("SAT") issued the Implementation Rules for Special Tax Adjustments (Trial), Guo Shui Fa (2009) No. 2 (the "Rules").

ChinaTax
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On January 8, 2009, the State Administration of Taxation ("SAT") issued the Implementation Rules for Special Tax Adjustments (Trial), Guo Shui Fa (2009) No. 2 (the "Rules"). The Rules provide guidance for transfer pricing, advanced pricing arrangements, cost sharing agreements, controlled foreign corporations, thin capitalization, and general anti-tax avoidance. The special tax adjustments were provided in the new Corporate Income Tax Law and its implementation rules; both came into effect on January 1, 2008. The Rules have provided more detailed guidance on the special tax adjustments. The Rules replace several tax circulars on transfer pricing previously issued and are retroactively effective from January 1, 2008.

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