On 13 July 2016, China's State Administration of Taxation issued Announcement 42 on the Enhancement of the Reporting of Related Party Transactions and Administration of Contemporaneous Documentation. The Announcement includes regulations to replace certain aspects of Circular No. 2/2009 on Implementation Measures for Special Tax Adjustments, including the introduction of three-tiered documentation requirements based on Action 13 of the OECD BEPS Project. However, Announcement 42 does not incl…