国家税务总局正式发布《特别纳税调整实施办法(试行)》

第四十九 条预约定价安排适用于自企业提交正式书面申请年度的次年起3至5个连续年度的关联交易。 预约定价安排的谈签不影响税务机关对企业提交预约定价安排正式书面申请当年或以前年度关联交易的转让定价调查调整。

Article 49： The APA is applicable to the associated transactions with a continuous term for 3 to 5 years starting from the second year that the enterprise submits the formal application. Signing on the APA has no influence on the transfer pricing investigation and adjustment on the associated transactions, which occurred during or before the year in which formal applications were made.