How easy will it be for tax authorities to obtain price information from outside China when necessary as provided in Article 22 of the Affiliate Tax Rules?
Legally the tax authorities have the right to obtain information from other jurisdictions. This comes under the information exchange section of tax treaties. But it will be a difficult and lengthy process. In practice PRC embassy official, as envisaged in the provisions, will have little inclination to chase information on prices. It is unlikely that in their busy schedules they will make the effort to find out the wholesale price of, for example, film or soya beans.
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