China’s tax authority in 2016 issued guidance concerning the administration of related-party declarations and contemporaneous documentation, and recently issued an announcement clarifying that certain provisions of country-by-country (CbC) reporting will not apply for the CbC report for 2016.
The 2016 guidance is known as Announcement 42, and the 2017 guidance is known as Announcement 46.
The exchange of information measures were included as part of the CbC reporting measures in China pursuant to Announcement 42. In particular, the tax authorities may implement information exchange for CbC reporting pursuant to a treaty, agreement or arrangement between China and a foreign counter-party. Also, the tax authorities may, at the time of implementation of a “special tax investigation,” require the taxpayer entity to provide a CbC report when the tax authorities are unable to obtain the CbC report through an information exchange mechanism.
China’s State Administration of Taxation (SAT), International Taxation Department, made the following interpretations with regard to measures included in Announcement 46:
Read a December 2017 report prepared by the KPMG member firm in China
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