On 17 September 2015, China's State Administration of Taxation (SAT) issued a discussion draft of the Implementation Measures for Special Tax Adjustments that updates upon and would replace trial measures introduced in Circular No. 2/2009. The draft covers a number of areas including, transfer pricing, advance pricing agreements, cost-sharing agreements, controlled foreign companies, thin capitalization, and GAAR.
Some of the main changes introduced in the draft are summarized as follows.
…