According to Guo Shui Fa [2009] No. 2 "Implementation Measures of Special Tax Adjustments (Trial Version)", Guo Shui Han [2009] No.188 "Strengthening of Transfer Pricing Management and Related Issues", and Guo Shui Han [2009] No.363 "Strengthening of Monitoring and Investigation of Cross-border Transactions", the following enterprises should prepare contemporaneous documentation of relatedparty transaction in the previous year before 30 May of each year:
1) Sales amount of related party transactionin the years 2008 and after (the amount of processing trade is calculated as the annual import and exportcustoms clearance prices) is over RMB 200 million, or other related party transaction amount (financing from related party is calculated including receipt and delivery of interest) is over RMB 40 million.
2) The period of tracing management is from year 2008 (whether the sales amount of related party transaction or other related party transaction amount achieves the required conditions, contemporaneous documentation of the tracing management years should be prepared).
3) If the firms established in China by transnational enterprise which undertake single producing (C.M.T or processing imported materials), distribution, contract R&D or other limited functions and risks, produced losses in 2008 or the years after, contemporaneous documentation of the loss year should be prepared, whether the sales amount of related party transactionor other related party transaction amount achieves the required conditions.

    All the members of Zhaochen Deye have learned about Guo Shui Fa [2009] No. 2 "Implementation Measures of Special Tax Adjustments (Trial Version)" and "Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations" to do the business on transfer pricing tax risk surveyand related ones. We provide apackage of service from transfer pricing plan, documentation production to APA, etc.

Contemporaneous documentationand APA service includes:
◇ Assist to produce the related documentation on transfer pricing.
◇ Assist to reply to transfer pricing tax survey.
◇ Assist to do the application of APA.
◇ Popularize information and knowledge about transfer pricing and help to produce related documentation etc.