At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-28. Tax authority: State Taxation Administration (STA). Summaries are simplified; check the linked official source before relying on them.
The law
#Enterprise Income Tax (EIT) Law Chapter 6 (arts. 41 to 48) and its Implementing Regulations arts. 109 to 123; STA Announcement [2016] No. 42 (related-party reporting and contemporaneous documentation); STA Announcement [2017] No. 6 (special tax investigations, adjustments and MAP); APA rules in Announcement [2016] No. 64. China follows the arm's length principle and draws on OECD/BEPS work but the domestic rules govern. The tax year is the calendar year.
Documentation
#Contemporaneous documentation in three parts. Master File: if annual related-party transactions exceed RMB 1 billion, or the enterprise has cross-border related transactions and its group already prepared a master file; due within 12 months of the ultimate parent's year end. Local File: if transfers of tangible goods exceed RMB 200 million, financial assets RMB 100 million, intangibles RMB 100 million, or other related transactions RMB 40 million; due by 30 June of the following year. Special File for cost sharing agreements and thin capitalisation (same date as Local File). Exempt: transactions covered by an APA, and enterprises with only domestic related parties. In Chinese, sealed and signed, provided within 30 days of a request, kept 10 years.
Methods
#CUP, resale price, cost plus, TNMM, profit split and other methods consistent with the arm's length principle (Announcement 2017 No. 6 art. 16; valuation methods allowed for intangibles and equity). Interquartile range is common; if a taxpayer's profit is below the median of the comparables, the adjustment is in principle to no less than the median (art. 25). Year-by-year testing; the less complex party is the tested party.
Penalties
#TP adjustments carry special interest at the PBOC RMB base lending rate plus 5 percentage points (Implementing Regulations art. 122); only the base rate applies if the enterprise filed its related-party forms and provided documentation. Adjustments can reach back 10 years (art. 123). Late or missing filings: Tax Collection and Administration Law art. 62 (up to RMB 2,000, RMB 2,000 to 10,000 if serious). Refusing to provide information: art. 70 (up to RMB 10,000, RMB 10,000 to 50,000 if serious).
Pillar Two
#Mainland China has not enacted Pillar Two: there is no IIR, UTPR or QDMTT and no Chinese GloBE filing. It is not listed on the OECD central record of qualified rules (current to 1 May 2026). Chinese entities still feed data into GIRs filed elsewhere, and Hong Kong SAR has its own rules from 2025.
Other rules
#Unilateral and bilateral APAs (Announcement 2016 No. 64). Thin cap: related-party debt-to-equity 2:1 (5:1 for financial firms) under Caishui [2008] No. 121, unless a thin cap special file shows arm's length. Payments to overseas related parties that perform no functions can be fully adjusted (Announcement 2017 No. 6 art. 37). No CbC notification requirement; the CbC report is a schedule of the annual related-party forms. Corresponding and compensating adjustments handled through MAP.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Annual EIT return and final settlement Within five months after year end (EIT Law art. 54), so 31 May for the calendar tax year. Extensions only under the Tax Collection and Administration Law procedure. | 5 months after year end (e.g. Jun 1, 2026) (moved from May 31, 2026, a Sunday) | All resident enterprises and non-resident enterprises with an establishment in China. | Enterprise Income Tax Law, art. 54 |
| 2 | Annual Related-Party Transaction Reporting Forms (2016 version) Filed together with the annual EIT return (Announcement 2016 No. 42, item 1), so by 31 May. | With Annual EIT return and final settlement (e.g. Jun 1, 2026) (moved from May 31, 2026, a Sunday) | Resident enterprises taxed on actual profits and non-resident enterprises with an establishment that file on actual profits, if they have related-party transactions (no minimum). | STA Announcement 2016 No. 42 |
| 3 | Country-by-Country report (schedule of the related-party forms) Filed with the annual related-party forms, so with the EIT return by 31 May. There is no separate CbC notification in China. | With Annual EIT return and final settlement (e.g. Jun 1, 2026) (moved from May 31, 2026, a Sunday) | Chinese resident ultimate parent with prior-year consolidated revenue above RMB 5.5 billion, or a resident entity designated as the reporting entity. Tax authorities may also request it during an audit if the group filed nowhere, or exchange failed. | STA Announcement 2016 No. 42, items 5 and 8 |
| 4 | Local File (contemporaneous documentation) Prepared by 30 June of the year after the transaction year; not filed. Provide within 30 days of a request. Keep 10 years. | Fixed calendar date (e.g. Jun 30, 2026) | Annual related transactions above any of: tangible goods transfer RMB 200 million (toll processing at customs value), financial asset transfer RMB 100 million, intangible transfer RMB 100 million, all other related transactions RMB 40 million. Not needed for APA-covered transactions or if all related parties are domestic. | STA Announcement 2016 No. 42, items 13 and 19 |
| 5 | Special Issue File (cost sharing or thin capitalisation) Same timing as the Local File (by 30 June of the following year). | Fixed calendar date (e.g. Jun 30, 2026) | Enterprises with a cost sharing agreement, or whose related-party debt-to-equity ratio exceeds the standard ratio and want to show arm's length. | STA Announcement 2016 No. 42, items 15 to 19 |
| 6 | Master File Prepared within 12 months after the ultimate parent's fiscal year end (count from the group year end). Provide within 30 days of a request. | 12 months after year end (e.g. Dec 31, 2026) | Annual related-party transactions above RMB 1 billion, or cross-border related transactions where the group's ultimate parent has prepared a master file. | STA Announcement 2016 No. 42, items 11 and 19 |
| 7 | Provide contemporaneous documentation on request Within 30 days of the tax authority's request; if force majeure, within 30 days after it ends. | Within 30 days of a tax authority request | Any enterprise required to prepare Master, Local or Special files. | STA Announcement 2016 No. 42, items 19 and 20 |