What are the aspects of the framework for the administration system for the taxation of transfer pricing as stated in the Transfer Pricing Notice?
The Transfer Pricing Notice lays down the framework for a highly efficient administration system for taxation of transfer pricing. The key elements include competent specialist audit teams to inspect the transfer pricing aspects of foreign enterprises' transactions and a database for administration of transfer pricing using information gathered from other government authorities such as the Administrations of Industry and Commerce, PRC Customs authorities and banks. In addition, departments dedicated to the tax administration of transfer pricing will be established within tax authorities in areas where foreign-invested enterprises ("FIEs") are concentrated.
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