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Exchanges and Cooperation

◇ Multilateral Exchanges and Cooperation
◇ Bilateral Exchanges and Cooperation
◇ Expanding EOI Network
◇ Expanding Tax Treaty Network

Being an active player in international tax arena, the SAT works closely with international partners in exchange of information,cross-border collaboration and multilateral actions. The SAT is committed to cooperating with other tax jurisdictions to ensure an open, vibrant and level playing field, contributing to the balanced and sustainable development of the global economy.

Multilateral Exchanges and Cooperation
The SAT has been active in exchanges on tax matters under the G20 framework,including the Base Erosion and Profit Shifting (BEPS) Project. It has stepped up its cooperation with the OECD, IMF and BRICS countries. It has advocated the FTA cooperation format and spared no effort in establishing the JITSIC platform. In 2013, the SAT signed the Convention on Mutual Administrative Assistance in Tax Matters . Then in 2015, the SAT signed its first Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information .
Exchanges and Cooperation under the G20 Framework
Since 2013, China has actively participated in the BEPS project initiated by the OECD with the authorization from G20. China worked hard in attending meetings on various topics, doing research, holding negotiations and giving feedback. So far the SAT has attended 86 BEPS meetings and negotiations, and expressed China's positions and recommendations on all the 15 actions. Drawing on the BEPS deliverables, the SAT has promulgated a range of policies concerning international taxation, such as anti-avoidance, non-resident taxation, and outbound investment taxation, etc.
Participation in FTA Activities
The SAT has sent delegates to attend seven FTA sessions since 2005. In 2015, It attended two FTA Bureau meetings and engaged in the research of 9 programmes,i.e. overseas compliance, JITSIC, large business, MAP, tax administration's capacity building, small and medium-sized enterprises, electronic service, advanced analysis, and compilation of Tax Administration publications.
The 10th FTA Meeting is to be held in Beijing from 11-13 May 2016.

Participation in OECD Activities
The SAT started to take part in some CFA work from 1996, and such involvement has deepened since China became a formal CFA observer in 2004. In 2015, the SAT and the OECD signed its MoU for Cooperation 2016-2018 , which covers the various forms of cooperation in 19 areas including tax policy, tax administration,and international taxation. Key results:
◆ The SAT attended the technical meetings held by CFA and its subsidiaries as well as Global Forum on Transparency and Exchange of Information for Tax
Purposes, and served as the vice-chair of No. 10 Working Party on Exchange of Information and Tax Compliance.
◆ The SAT actively participate in revising the Model Tax Convention on Income and on Capital, and OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
◆ The SAT sent tax experts to instruct at OECD Global Relation Programme events.
◆ The SAT sent over 100 tax officials to attend Global Relation Programme events held in OECD Multilateral Tax Centers in Seoul, Ankara, Budapest, Vienna and Mexico.
◆ The SAT worked with the OECD to hold seminars in China and invited OECD experts and tax officials from other countries to attend the seminars.
◆ The SAT and the OECD have set up the "OECD-SAT Multilateral Tax Center" to provide training courses for tax officials from developing countries in Asia,
Africa and Latin America, etc.

Cooperation with IMF
In 2015, the SAT carried out its 3-year technical cooperation agreement (2013-2015) with the IMF. In 2015, the SAT received two expert delegations (Missions) from the IMF, with one focusing on the topic of tax administration law and the other on the PIT. It also accepted seven short-term visiting experts researching on large business management.
Participation in the BRICS Activities
The mechanism was first established in 2013 for the BRICS Tax Commissioners to meet regularly. In November 2015, the SAT Commissioner Wang Jun attended the Meeting of BRICS Heads of Tax Authorities held in Russia, during which attending parties reached consensus on cooperation in the following areas:
1) implementing the BEPS deliverables; 2) implementing the Common Reporting Standards for financial account information; 3) providing technical assistance to developing countries; and 4) increasing the influences of the BRICS tax authorities.
Pushing Forward SGATAR Reform
The Study Group on Asian Tax Administration and Research (SGATAR) is the only official organization for collaborations on tax administration in the Asia-Pacific region. In 2013, the organization started its reform, aiming at enhancing
the performance of tax administrations through encouraging collaboration among its members. As a member of the organization, the SAT has actively involved in STAGAR's reform agendas. At the 45th SGATAR Meeting in 2015, the SAT took part in discussions on all reform items, such as cooperation framework paper and mobilization of training resources.
Helping Developing Countries with Capacity Building
The SAT helps developing countries in Asia, Africa and Latin America with their capacity building in a variety of ways, including legislative consultation, topical
discussions, expert support, experience sharing and technical assistance. Two seminars on Tax Administration and Taxpayer Service were held in China in 2015, with 82 tax officials from 18 Asian, African and Latin American countries participated.

Bilateral Exchanges and Cooperation
In accordance with the bilateral cooperation agreements and MoUs with the tax administrations of Korea, Japan, the Netherlands, France, Mongolia, Argentina,Kenya, Kyrgyzstan and Ethiopia, the SAT has engaged in bilateral meetings and exchanges with their leaders or at operational level. the SAT regularly invites foreign tax experts to give lectures in China. In 2015, tax experts from France, the UK, and the Netherlands were invited to give lectures on revenue statistics and analysis, PIT, EOI, risk management, taxpayer service, and anti-avoidance.
As part of its talent development program, the SAT selects and seconds on a regular basis tax officials to participate in internships or topical trainings outside of mainland China. In 2015, eight tax officials from the Elite Tax Experts Program and three young talented tax officials were sent to work as interns in the Hong Kong offices of the four most famous accounting firms in the world. Two young tax officials were sent to work in International Bureau of Fiscal Documentation in the Netherlands. The SAT also selected and sent tax officials to the Netherlands,France, the UK, Germany, Austria, Canada, the US, Korea, Brazil and Australia to receive training on the topics of compliance risk management, international taxation, large business audit, tax administration and performance management,BEPS, transparency and exchange of information for tax purposes, taxpayer service, and general anti-avoidance.
Table 10 illustrates the foreign tax administrations visited China and held bilateral communications and activities with the SAT in 2015.

Expanding EOI Network
In the 1990s, the exchange of information on request was the main form of EOI.The SAT responded to specific requests from about ten countries including the US and the UK, and sent out its specific requests mainly to six countries like Japan and the US. As China blends into the world economy in the 21st century, its rate of exchange of information for tax purposes has accelerated. China has maintained stable working relationship with over 50 tax jurisdictions in aspect of EOI in 2015.the SAT reviews over 400 cases of EOI on request annually, and has started to pilot EOI with other countries through the JITSIC platform.
China signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in August 2013 (see Table 11). The Convention became binding for China on 1 February 2016 and will be implemented by China on 1 January 2017.China also signed TIEAs with 10 tax jurisdictions including Bahamas, British Virgin Islands, Isle of Man, Guernsey, Jersey, Bermuda, Argentina, Cayman Islands,San Marino, and Liechtenstein, and all of the TIEAs are in force and implemented(see Table 12). China's mutual administrative assistance network has expanded to cover major trade partners, and low tax jurisdictions which have frequent economic ties with China.
In 2014, China promised that the Standard for Automatic Exchange of Financial Account Information would be implemented by China in September 2018, and now it is preparing for the work. In the future, China will be able to combat tax evasion and avoidance more effectively using the information of foreign accounts, which acquires through AEOI with major economies and financial hubs in the world.

Expanding Tax Treaty Network
China started its negotiation of tax treaties in 1981, and had signed 101 tax treaties with other countries and 2 arrangements with Hong Kong SAR and Macao SAR by the end of 2015. A tax treaty was also signed by Association of Relations across the Taiwan Straits (on behalf of Chinese Taipei) and Straits Exchange Foundation (on behalf of mainland China) in 2015.

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