Who is required to prepare contemporaneous transfer pricing documentation?

Parties that do not meet one of the following exemption requirements:

• Annual amount of related party tangible goods transaction is below RMB 200 million and the amount of the related party intangible goods transactions is below RMB 40 million;
• The transactions are covered by an Advanced Pricing Arrangement; or
• The foreign shareholding is below 50 percent and the enterprise only transacts with domestic related parties.