Announcement on Enterprise Income Tax Issues Relevant to the Payment of Expenses by Enterprises to Overseas Affiliates

关于企业向境外关联方支付费用有关企业所得税问题的公告

The tax authority may proceed with an adjustment for any expenses paid to an overseas affiliate not in compliance with the arm's length principle.

(Issued by the State Administration of Taxation on, and effective as of, March 18 2015.)

SAT Announcement [2015] No.16

With a view to further regulating and strengthening the administration of transfer pricing in connection with the payment of expenses by enterprises to overseas affiliates we, pursuant to relevant provisions of the PRC Enterprise Income Tax Law (the Enterprise Income Tax Law) and its Implementing Regulations, hereby announce to you transfer pricing issues relevant to the payment of expenses by enterprises to overseas affiliates as follows:

(国家税务总局于二零一五年三月十八日公布施行。)

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