The third branch of the Shanghai tax bureau has recently requested that more than 40 banks (including subsidiaries and branches) submit their transfer pricing documentation for the 2008 and 2009 financial years. The time frame of documentation submission is only 1-2 weeks rather than 20 days as specified in the transfer pricing regulations. This request appears to be one of the Mainland China’s State Administration of Taxation’s (SAT’s) measures aiming to identify potential audit targets for further examination. In addition to requesting transfer pricing documentation, the in-charge tax bureau has requested various other documents relating to operations and payments made to accounts located in foreign jurisdictions, including the United States, Canada, Japan, South Korea and Australia.
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