According to Article 17 of the "Announcement of the State Administration of Taxation on Matters Concerning Improving the Management of Related Party Declarations and Contemporaneous Materials" (State Administration of Taxation Announcement No. 42, 2016): "Documents on special matters related to thin capitalization include the following Content:

(1) Analysis of corporate debt solvency and debt raising capabilities

(2) Analysis of corporate group debt capabilities and financing structure

(3) ) Description of changes in the enterprise’s registered capital and other equity investments

(4) The nature, purpose and market conditions of the related-party debt investment at the time of acquisition

(5) Related-party debt investments. Currency type, amount, interest rate, term and financing conditions.

(6) Whether the non-related parties are able and willing to accept the above financing conditions, financing amount and interest rate.

(7) Enterprise. The status and conditions of the collateral provided to obtain debt investment.

(8) The status of the guarantor and the guarantee conditions.

(9) The interest rate and financing conditions of similar loans of the same period. .

(10) Conversion conditions for convertible corporate bonds

(11) Other information that can prove compliance with the principle of arm's length.