“Implementation measures of special tax adjustments” released by SAT for public consultation

As a member of the G20, China has expressed its strong support to Base Erosion and Profit Shifting (“BEPS”) Action Plans being studied by the OECD, the final report of which was issued on 5 October 2015, and has been deeply involved in the BEPS development process. It has been expected that the BEPS project would have a significant influence on the work of China’s State Administration of Taxation (“SAT”) in particular the issuance of comprehensive transfer pricing (“TP”) rules to replace the existing Guo Shui Fa [2009] No. 2 (“Circular 2”).