China expands contemporaneous documentation requirements
July 29, 2009
A regulation released earlier this month by China’s State Administration of Taxation (SAT) makes loss-making single-function enterprises submit transfer pricing contemporaneous documentation to justify their losses.
The circular, Guoshuihan 363, entitled Notice on Strengthening the Monitoring and Investigation of Cross-Border Related-Party Transactions and dated July 7 2009, requires such enterprises to prepare and submit contemporaneous documentation and other relevant materials, regardless of the exemption threshold, by June 20 of the year following the losses.
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