Tax Related Laws & Regulations
1.
The reported price of Controlled Transaction is two times or more than the Arm’s Length price assessed by the collection authorities-in-charge; or lower than 50% of the Arm’s-length price.2.
The increase in taxable income of the Controlled Transactions adjusted and assessed by the collection authorities-in-charge is more than 10% of the annual taxable income of the enterprise; and more than 3% of the annual net operating revenue.3.
A profit-seeking enterprise cannot produce transfer pricing report as required under Paragraph 1 of Article 22 thereof, and no other documents evidencing the transactions is Arm’s-length result.4.
The increase in taxable income of the Controlled Transactions, which are not disclosed in the report or transfer pricing document in accordance with Articles 21 to 22-1 by a profit-seeking enterprise, adjusted and assessed by the collection authorities-in-charge is more than 5% of the annual taxable income of the enterprise; and more than 1.5% of the annual net operating revenue.