Transfer pricing adjustments may be made in accordance with Circulars 3 and 16 “Internal Working Procedure (Trial) of Special Taxation Adjustment” and “Joint Assessment Procedure (Trial) for Key Cases of Special Taxation Adjustment”. Accordance with SAT Gong Gao (2014) No 54 of 29 August 2014, the taxpayer is sent a Notice of Tax Affairs and must send in contemporaneous transfer pricing documentation and other related material within 20 days of the issue date of the letter if the tax authority considers there is a risk of tax adjustments. The taxpayer may make adjustments and pay tax on its own initiative or request the tax authority to determine the transfer pricing methods and make the tax adjustments.
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