China's State Administration of Taxation has recently issued Public Notice No. 16 2015. The Notice, dated 18 March 2015, contains strengthened transfer pricing rules concerning service fees and royalties paid by a Chinese enterprise to a foreign related party, and clarifies the application of certain articles of the Enterprise Income Tax (EIT) Law. The main elements of the Notice are summarized as follows:
- Based on Article 41 of the EIT Law, any expense paid by a Chinese company to a foreign…