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Reporting of Contemporaneous Documentation

Writer:   |  Editor: Stephanie Yang  |  From: Shenzhen Tax Service, State Administration of Taxation  |  Updated: 2022-05-13


Enterprises above certain thresholds shall prepare and submit  contemporaneous documentation concerning related party transactions - master  file, local file, or special issue file –on a tax-year basis pursuant to  requirements of tax authorities.

[Materials Required]

Materials  Name



Materials  Conditionally Required

Where  thresholds for preparation of master file are met

Master  file


Where  thresholds for preparation of local file are met

Local  file


Where  thresholds for preparation of special issue file are met

Special  issue file


[Time Limit]

1.For Taxpayers

Contemporaneous document shall be submitted within 30 days upon  request from the tax authorities.

2.For Tax Authorities

Instantly after acceptance of materials that are complete,  compliant with the legal form, and fully filled out.


Results will be given by the tax authorities.

[Notice to Taxpayers]

1.Taxpayers are responsible for the authenticity and legality of  the materials they submit.

2.Taxpayers only need to visit tax authorities once if the  materials are complete and the statutory conditions for acceptance are  satisfied.

3.An enterprise shall prepare and submit contemporaneous  documentation concerning its related party transactions-master file, local file,  or special issue file-on a tax-year basis pursuant to requirements of the tax  authorities.

4.A master file should be prepared, if:

(1) an enterprise has cross-border related party transactions in  the year, and the ultimate holding enterprise that consolidates it into its  financial statements has prepared a master file; or

(2) the enterprise had related party transactions with an  aggregate value exceeding RMB 1 billion in the year.

5.For an enterprise's annual related party transactions, a local  file should be prepared, if:

(1) the sum of tangible property transfers exceeds RMB 200 million  (calculated based on the prices for import/export customs declaration for toll  manufacturing);

(2) the sum of financial asset transfers exceeds RMB 100  million;

(3) the sum of intangible property transfers exceeds RMB 100  million; or

(4) the sum of other related party transactions exceeds RMB 40  million.

In addition, if an enterprise carries on single production  activities of toll manufacturing or processing with imported materials, or  distribution or contractual research & development, for its foreign related  party, a reasonable profit level should be maintained in principle. In the event  of any loss, a local file should be prepared for the year in which such loss  occurs.

6.Special issue file includes cost contribution arrangement  special issue file and thin capitalization special issue file.

A cost contribution arrangement special issue file should be  prepared if an enterprise signs or executes a cost contribution arrangement.

A thin capitalization special issue file should be prepared if an  enterprise's related party debt-to-equity ratio exceeds the standard ratio and  requires explanation concerning compliance with the arm's length principle.

7.In case of execution of an advance pricing arrangement, an  enterprise is exempt from preparing any local file or special issue file for  related party transactions covered by such advance pricing arrangement, and the  sum of such related party transactions will not be included into the  enterprise's related party transaction value.

8.Master file preparation should be completed within 12 months of  the fiscal year end of the group's ultimate holding enterprise; and local file  and special issue file preparation should be completed prior to 30 June of the  year following the year in which related party transactions occur.  Contemporaneous documentation should be submitted within 30 days upon request  from the tax authorities.

9.No contemporaneous documentation is required for related party  transactions between an enterprise and its related party in China.

10.In case of failure to provide contemporaneous documentation  within the prescribed time limit due to any force majeure circumstance, an  enterprise shall provide the same within 30 days after the force majeure  circumstance ceases.

11.Addresses of taxpayer service halls and the website of e-tax  bureau are available on the web portals of tax authorities or by dialing the  12366 tax service hotline.


Free of charge.

(Note: The text above is a translation of the  Chinese version for reference only. In case of any discrepancy between the two  versions, the original published Chinese version shall  prevail.)