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Q&A Regarding to Master File (2)

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Q: What is the simplified and consolidated provision of master file?
A: For enterprise groups that need to prepare master file in accordance with regulations, if the enterprises in the group are under the jurisdiction of two or more tax authorities, they can choose the competent tax authority of any enterprise to proactively provide the main documents. When other companies in the group are required to provide the master file by the competent tax authority, they may be exempted from providing the master file after they have reported in writing to the competent tax authority that the group has actively provided the master file.

Q:
What are the criteria to provide the simplified and consolidated master file?
A:
In accordance with the requirements of the State Administration of Taxation Announcement No. 14 of 2018 (hereinafter referred to as "Announcement 14"), enterprises can provide simplified and consolidated master file if they meet the following criteria: first, the enterprises meet the requirements for the preparation of the master file in the State Administration of Taxation Announcement No. 42 of 2016; second, the enterprises of the group are under the jurisdiction of two or more tax authorities; third, the enterprises proactively provide the master file.

Q:
A certain enterprise group meets the requirements for simplified and consolidated the master file, if a subsidiary of the group is under the special tax investigation by the tax authority and has provided the master file in accordance with the requirement of the tax authority, can other enterprises of the group be exempted from providing the master file?
A:
The "proactive provision" mentioned in Announcement 14 refers to the situation where the enterprise provides the master file before the special tax investigation is carried out by the tax authority. "Providing the master file after the special tax investigation conducted by the tax authority" does not belong to the "proactive provision" situation described in Announcement 14, therefore, other enterprises of the group cannot be exempted from providing the master file. However, the simplified and consolidated provision procedure is still applicable to the group, it may choose the competent tax authority of one of the other enterprises to provide the master file proactively.

Q:
If an enterprise group has proactively provided the master file to the competent tax authority of the chosen enterprise of the group, what should other enterprises do if they are required to provide the master file?
A:
According to the requirements of Announcement 14, other enterprises only need to report in writing to the competent tax authority that the group has provided the master file, including the time of provision and the name of the tax authority that has received the master file, to be exempt from providing it.

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