Aiming at the huge revenue loss resulting from active transfer pricing activities by multinationals, SAT issued Implementing Rules for Negotiated Pricing for the Transactions Among Associated Enterprises to enhancing its anti-tax-evading controls. With this trend, Ms Mao Yi from F&T Center said, there are some difficulties in implementing APA rules in our current taxation system and economic environment.

1, Lacking of specialists and experience in APA: This will be the most center problem in implementing APA

2, Small scope of enterprises to implement: APA is still something relevant to only a few targets: the multinationals

3, Difficulty in price fixing: Both enterprise and authority need a great deal of information to work out their price to apply for or to be approved.

4, Time cost in procedure: APA is process of a great deal of negotiation, there are special requirement on people who are going to take part in the campaign.

5, Unilateral agreement may cause double taxation: Unilateral agreement lacks of recognition from other nations, it may cause double taxation.

6, Information disclosure of enterprises

7, Cooperation of other government departments: Tax officers will need the help from Custom House, Banks, Financial Departments, Foreign Affair Administration, etc.

Because of their composite knowledge structure and experience in handling legal issues, tax lawyers may have a unique effect in helping corporations fighting through their APA campaigns.