The SAT recently issued its inaugural annual APA Report, which includes an introduction to China's APA program, the implementation procedures and related forms, and the recent development of the APA practice in China, together with a statistical survey of China's APA program for the period from 1 January 2005 to 31 December 2009. The document titled China Advanced Pricing Arrangement Annual Report, published in December 2010, puts China in line with some national tax authorities, including the United States, Japan, Korea, Australia, Canada and Italy, to publicise comprehensive reports on their APA programs. By issuing a periodical disclosure of the developments of its APA program, the SAT hopes to achieve strengthened cooperation with the taxpayers, as well as a higher degree of transparency for the regulations within the PRC and guidelines for their application. It underscores the SAT’s interest in further developing and enhancing its APA program.
China's tax authorities signed 53 APAs during the five year period between 1 January 2005 and 31 December 2009. Forty one agreements were unilateral APAs and the remaining 12 agreements were bilateral APAs. Interestingly, the figures show an increasing trend toward bilateral APAs being successfully negotiated, while the number of successful unilateral APAs per annum decreases. In 2009, the number of bilateral APAs signed was seven, exceeding the five unilateral APAs signed in the same year.