China alert - Issue 36, September 2011
China's State Administration of Taxation (SAT) issued the circular Guoshuifa  No. 2 - "Implementation Measures of Special Tax Adjustments (Provisional)" (Circular 2) in early 2009, stipulating the detail requirements for the preparation of transfer pricing contemporaneous documentation (TP documentation) for the first time. Since then, the administration of TP documentation has always been a focus of the SAT. By reviewing the TP documentations collected from taxpayers, the SAT intends to establish a foundation for other types of anti-avoidance practices.