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(From Business Daily Update)
Author: y China's State Administration of Taxation (SAT) has issued the Implementation Rules on Advance Pricing Agreement (APA) for Related Party Transactions. APA is a binding agreement between the tax authority and a taxpayer; and applies an agreed-upon transfer pricing method (TPM) to specified transactions between the taxpayer and a related party/parties. China first addressed the issue of APAs in 1998 when the SAT issued the Taxation Management Regulations for Business Transactions Between Associated Enterprises. In September, 2002, the State Council issued the Implementation Rules of Tax Collection and Administration Law, Article 53 of which provides that taxpayers may apply to the tax authorities for APAs. In practice, more than 130 unilateral APAs have been completed so far and at least one multinational corporation has applied for a bilateral APA. The …