IT has been reported that the Shaanxi Provincial State Tax
Bureau, has concluded China’s first thin capitalisation audit case. Besides thin
capitalisation, the case also involves the investigation of tangible goods
transactions and equity transfer. During the process, the SAT was also involved
in providing support to local in-charge tax authorities.
Taxpayers have been advised to closely monitor their financing
arrangements and debt-to-equity ratios in particular. Taxpayers have been asked
to prepare proper documentation where the threshold ratios are exceeded in order
to secure interest expense deductions, avoid the additional five percent penalty
component of the interest levy, and mitigate transfer pricing adjustment
risks.
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