View this page in: 简体中文版 Jan 2009, Issue 1Unveiling of long-awaited Special Tax Adjustments Implementation Measures China's new Corporate Income Tax Law ("CIT Law"), together with its Detailed Implementation Regulations ("DIR"), introduced a set of anti-avoidance measures in Chapter 6 - Special Tax Adjustments. It may well be the most complex chapter of the CIT Law, encompassing not only exploratory new concepts such as cost sharing, controlled foreign corporations, thin capitalisation, general anti-avoidance, but also imposing mandatory contemporaneous transfer pricing documentation requirements, that could altogether cause significant impact to taxpayers.
On 8 January 2009, the State Administration of Taxation (the "SAT") formally approved a circular entitled Guo Shui Fa [2009] No. 2 ("Circular 2"), and distributed it on 9 January 2009. Circular 2 contains the final version of the "Implementation Measures of Special Tax Adjustments (Trial)" ("the Measures"), which lay out detailed rules on administering all the aspects covered by special tax adjustments.
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