May 2017 - SAT INTEGRATING BEPS ACTION PLANS 8 TO 10 AND ACTION PLAN 14

On 17 March 2017, the State Administration of Taxation (“SAT”) released its long-awaited Bulletin on Special Tax Investigations, Adjustments and Mutual Agreement Procedures (“Bulletin 6”), thus largely completing the revision of the transfer pricing specific clauses of the old Circular 2 concerning Special Tax Adjustments.

In response to the OECD Action Plans 8 to 10, 13 and 14, the SAT initially issued a Discussion Draft in May, 2015 (“Discussion Draft”) for public consultation. The Discussion Draft was subsequently withdrawn, with the introduction of Bulletin 42   dealing with OECD Action Plan 13 in July, 2016, and an indication that further announcements would be made in the future.  Bulletin 64 dealing with Advanced Pricing Arrangement was subsequently issued in October, 2016.

Document

SAT INTEGRATING BEPS ACTION PLANS 8 TO 10 AND ACTION PLAN 14