On 19 December 2017, China’s tax authority issued a public notice No. 46 clarifying country-by-country (CbC) reporting matters, that illustrate certain provisions of country-by-country (CbC) reporting will not apply for the CbC report for 2016.

Whereas the Multilateral Convention on Mutual Administrative Assistance in Tax Matters shall have effect for taxable periods beginning on or after 1 January of 2017 in respect of China in order to align the public notice on matters regarding refining the filing of related party transactions and administration of contemporaneous transfer pricing documentation (Public Notice of the State Administration of Taxation [2016] 42, hereinafter as Public Notice 42) with the Convention, issues related to Country-by-Country reporting are hereby clarified Article 7 and Article 8 of Public Notice 42 will not be applicable to Country-by-Country report related to 2016 fiscal year.