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SAT gives details of sample documentation review in China

July 28, 2010

A new circular telling local tax bureaux to carry out a nationwide evaluation of taxpayers’ 2008 and 2009 contemporaneous transfer pricing documentation (CTPD) was released on July 12 by the Chinese tax authorities.

Circular 323 (Guo Shui Han [2010] No 323) titled Notice of the SAT Regarding the Sample Review of Contemporaneous Transfer Pricing Documentation continues the Chinese onslaught on transfer pricing arrangements and covers all businesses subject to CTPD requirements. These include six categories of companies:

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