China: The SAT to conduct critical review of Chinese contemporaneous transfer pricing documentation 

Jul 2010
  
The State Administration of Taxation ("SAT") recently released Guo Shui Han [2010] No.323 - Notice of the SAT Regarding the Sample Review of Contemporaneous Transfer Pricing Documentation ("Circular 323"), mandating local authorities to conduct a thorough review of select taxpayers' contemporaneous transfer pricing documentation ("CTPD") and report their assessments by 31 October 2010.  This appears to be a quality-review initiative, to help determine how successful taxpayers have been in meeting documentation requirements and decide if revisions need to be made to the SAT's CTPD regulations.  In this article, we share further details on this circular including which taxpayers are likely to be affected by this circular, what aspects of CTPD local tax authorities will be analysing and analysis about how taxpayers can prepare for this review.

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