Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's-Length Transfer Pricing Article 21

When filing income tax returns or making their current final report, profit-seeking enterprises shall stand on the prescribed format; disclose the information regarding Affiliated Enterprises or Related Parties set forth in Subparagraph 1 and 2, Paragraph 1 of Article 4 hereof, respectively, the structure chart of the affiliated or controlling relationship with shareholding ratio, as well as the information regarding the transactions between the profit-seeking enterprises and such Affiliated Enterprises and Related Parties. In the case of a constituent entity of an MNE Group, the profit-seeking enterprise shall disclose the following information: the domestic entity appointed by the MNE Group to submit the master file, as set forth in Paragraph 1, Article 21-1 hereof; the Ultimate Parent Entity, the domestic entity appointed by the MNE Group to submit the country-by-country report or the Surrogate Parent Entity, as set forth in Paragraphs 1, 2 and 3 of Article 22-1 hereof, when filing income tax returns.