Legal basis: Article 36 of People's Republic of China (PRC) Tax Administration Law. The tax authorities have the right to make reasonable adjustments to the business dealings between enterprises, institutions and places engaged in production and business operations established by foreign enterprises in China and their affiliated enterprises.
Article 41 of the Enterprise Income Tax Law of People's Republic of China (PRC), if the business dealings between an enterprise and its related parties do not conform to the principle of independent transactions, thus reducing the taxable income or income of the enterprise or its related parties, the tax authorities have the right to make adjustments in a reasonable way. The costs incurred by an enterprise and its related parties in developing or transferring intangible assets or providing or accepting labor services shall be shared according to the principle of independent transaction when calculating taxable income.