China transfer pricing documentation guide
January 21, 2009
Steven Tseng and Chi Cheng, KPMG China
The ultimate source of China’s reporting requirements is the corporate income tax law (the CIT law) and the implementation rules (implementation rules), which both became effective on January 1 2008. These laws formally introduced both contemporaneous documentation and annual filing requirements into Chinese law. According to article 43 of the CIT law and article 114 of the implementation rules, a company under audit or “whose business scope and operation model are similar to the enterprise under investigation” must provide the following (quoted directly from article 114):
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