The State Administration of Taxation (“SAT”) hereby issues the China Advance Pricing Arrangement (“APA”) Annual Report (2012). This fourth APA annual report released by the SAT introduces China’s APA mechanisms, procedures and practices, and provides statistics for 2005 through 2012 accompanied by an analysis of the statistics.

An APA refers to an arrangement whereby an enterprise applies in advance to negotiate and reach agreement with the tax authority in respect of the transfer pricing methods and corresponding calculation methods to be applied to its related party transactions for future years in accordance with the arm’s length principle. An APA may be categorized as unilateral, bilateral or multilateral based on the number of competent authorities involved in the APA.

Regularly releasing APA annual reports is a major initiative of SAT to regulate APA administration and enhance transparency of the APA program. In its executive summary, the 2012 report provides a brief description of the APA program operation and office structure in 2012, and sets out the factors the SAT considers when prioritizing APA requests, which further demonstrates SAT’s determination to enhance transparency and taxpayer service.

The SAT will continue to compile and issue APA annual reports for future years.

《中国预约定价安排年度报告(2012)》

《China Advance Pricing Arrangement Annual Report(2012)》

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