Notice of Inspection on transfer pricing contemporaneous documentation

Posted by admin on July 27, 2010 under China Tax | Be the First to Comment

Guoshuihan No. 323 (2010)

 To national tax bureaus and local tax bureaus in each province, autonomous region, municipality directly under the central government, municipality separately list on the state plan:

 Serving the purpose of implementing the new Enterprise Income Tax Law and its enforcement regulations, enhancing the supervision on contemporaneous documentation, knowing the compliance situation and relative problems in enterprises’ preparing contemporaneous documentation, State Administration of Taxation decides to make a random inspection on contemporaneous documentation preparing nationwide. The following is the explicit detailed requirements:

Firstly, tax authorities in provinces organize the random inspection on contemporaneous documentation under their administration area, which should cover two tax year of 2008 and 2009.Each competent tax departments should according to enterprises’ related-parting reporting data, calculated the enterprises list which ought to prepare contemporaneous documentation in the province annually, strictly follow statistical sampling method to select samples(the quantity of selecting samples for each year should not be lower than 5% in the whole),and organize to inspect the situation of sample enterprises’ contemporaneous documentation. The department of big enterprises taxation managing in State Administration of Taxation will separately arrange the contemporaneous documentation inspection for those enterprises directly contacted with State Administration Taxation.

Second, each tax authority should fill in contemporaneous documentation preparing situation table annually on the basis of inspection. (See annex one), make an analysis report after aggregation. The aforesaid analysis report shall be reported to the State Administration of Taxation (International Taxation Department) through FTP before October 31 2010.

Annex:

1. ____ (year) contemporaneous documentation preparing situation table

2. ____ (year) sample report on situation analysis for contemporaneous documentation preparing situation.