China's State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular 2), the so-called “Master Guide” to Chinese transfer pricing. For the proposed update of Circular 2, the SAT has just released a discussion draft of "Implementation Measures of Special Tax Adjustment", which makes direct reference to various draft recommendations proposed in the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plans.
Tax payers should take note of the following significant changes:
|
|
|
|
|
|
|
This is yet another example of the impact the OECD BEPS project is having in triggering ambitious reforms in many national tax systems. We expect an avalanche of such National initiatives over the coming months once BEPS is finalised in October.