The China State Administration of Taxation (SAT) has issued Guo Shui Han [2009] No. 601 on the administration of corproate income tax withdolding for non-residence enterprise (e.g. dividend, interest, royalties). (9 January 2009)
China tax authorities has issued furhter circulars on China transfer pricing administration, e.g. Guo Shui Han [2009] No. 188, Guo Shui Han [2009] No. 363 in 2009.
According to Guo Shui Fa [2009] No. 3, you need to justify the commercial substance and comply with certain documentation requiements when ealing with equity transfer transactions where both parties are non-resident enterprises and where the transaction occurs outside Chinese territory.
