中国税务商务(PDF 4页)

It is not uncommon for foreign investment
enterprises (FIEs) in the PRC to import raw
materials and export finished goods to associated
enterprises. The SAT issued two circulars in late
1998, Guoshuifa [1998] No.59 and No.25,
requiring the tax authorities to take a closer look
at transfer pricing issues. Such FIEs will be the
next target of examination.
According to the transfer pricing regime,
transactions between associated enterprises
should be at arm's length prices. If the arm's
length principle is violated, the income tax laws
empower the tax authorities to make transfer
pricing adjustments for up to three years. In more
serious cases, the adjustments could be made for
up to ten years.
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