Accordingto Guo Shui Fa [2009] No. 2 “Implementation Measures of Special Tax Adjustments(Trial Version)”, Guo Shui Han [2009] No.188 “Strengtheningof Transfer Pricing Management and Related Issues”, andGuo Shui Han [2009]No.363 “Strengthening of Monitoringand Investigation of Cross-border Transactions”, thefollowing enterprises should prepare contemporaneous documentation of relatedparty transaction in the previous year before 30 May of each year: sales amount of related party transactionin the years 2008 and after (theamount of processing trade is calculated as the annual import and exportcustoms clearance prices) is over RMB 200 million or other related partytransaction amount (financing from related party iscalculated including receipt and delivery of interest) is over RMB 40 million the period of tracing management is fromyear 2008 ( whether the sales amount ofrelated party transaction or other related party transaction amount achieves the required conditions, contemporaneousdocumentation of the tracing management years should be prepared) if the firms established in China bytransnational enterprise which undertake single producing (C.M.T or processing imported materials),distribution, contract R&D or other limited functions and risks, producedlosses in 2008 or the years after, contemporaneous documentation of the lossyear should be prepared, whether the sales amount of related party transactionor other related party transaction amount achieves the required conditions
All the members of Mingrui have learned about Guo Shui Fa[2009]No. 2 “Implementation Measures of Special TaxAdjustments (Trial Version)”and“Transfer Pricing Guidelines for Multinational Enterprises and TaxAdministrations”.We also have bought OSIRIS databaseand Ownership structure data base of BVDwhich is trusted by SAT to do thebusiness on transfer pricing tax risk surveyand related ones. We provide apackage of service from transfer pricing plan,documentation production to APA,etc. Contemporaneousdocumentationand APA service includes: ◇Assistto produce the relateddocumentation on transfer pricing ◇Assistto reply to transfer pricing taxsurvey ◇Assistto do the application of APA ◇Popularizeinformation and knowledge about transferpricing and help to produce relateddocumentation etc. ◆ For further information, please contact yourregularCPA or call our professional on duty |