China: Transfer pricing documentation | KPMG | GLOBAL

China: Transfer pricing documentation, related-party reporting guidance from BEPS project

China: Transfer pricing documentation

The State Administration of Taxation today released new rules concerning the reporting of related-party transactions and of contemporaneous transfer pricing documentation. The new rules will apply for fiscal years beginning from 1 January 2016.


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The guidance, Announcement 42 (13 July 2016), replaces existing regulations and guidelines, and generally implements into China’s tax law the OECD’s base erosion and profit shifting (BEPS) Action 13 recommendations for transfer pricing documentation—including the country-by-country reporting and “Master file” and “Local file” requirements.

The guidance also replaces and revises the existing related-party transaction reporting forms that are filed with corporate income tax returns.

KPMG observation

Tax professionals in China observe Announcement 42 needs to be considered to be the first of a series of regulations for implementing the BEPS recommendations into China’s tax law.


Read a July 2016 report [PDF 319 KB] prepared by the KPMG member firm in China: State Administration of Taxation issues announcement on the enhancement of the reporting of related-party transactions and administration of contemporaneous documentation

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