国家税务总局关于修订《关联企业间业务往来税务管理规程》的通知 Administration of Tax on Business Transactions Between Affiliated Ent

rprise.

　　Article 48　Adoption of the method of advance pricing arrangement.

　　In order to reduce the cost of tax audits in connection with transfer pricing in business transactions between affiliated enterprises， enterprises shall be permitted to propose principles and calculation methods for transfer pricing in the course of trading between the enterprise and its affiliated enterprises. After the competent tax authority has analyzed and confirmed such principles and methods， enterprises shall use the same as the basis for calculating the deemed taxable income of the enterprise from transactions with its affiliated enterprises or for determining a reasonable range of sales profit rates. Any enterprise that wishes to use the method of advance pricing arrangement shall submit an appl

ication and relevant information， and complete an Application Form for Confirmation of Advance Pricing. Following examination and approval， the competent tax authority shall execute an advance pricing agreement with the enterprise and supervise the implementation thereof.

　　PART TWELVE　SUPPLEMENTARY PROVISIONS

　　Article 49　All documents and forms mentioned herein are set forth in an Annex hereto， entitled Manuscript of the Procedures for Tax Auditing， Investigation and Tax Adjustment of Business Transactions Between Affiliated Enterprises.

　　Article 50　Enterprises other than foreign-invested enterprises and foreign enterprises in China shall be handled in accordance with these Rules.

　　Article 51　The State Administration of Taxation shall be in charge of the interpretation of these Rules.

　　Article 52　These Rules shall be implemented as of the date of promulgation. In the event of any conflict between implementing procedures for tax administration promulgated previously and these Rules， these Rules shall prevail

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