In accordance with the "Measures for Special Tax Adjustment (Trial)" (Guoshui Fa [2009] No. 2) and related regulations, qualifying enterprises must prepare the comparable data for the same period of the year in which related-party transactions occurred by May 31 of the following year. Furthermore, the "Notice on Strengthening the Monitoring and Investigation of Cross-Border Related-Party Transactions" (Guoshui Han [2009] No. 363) explicitly stipulates that enterprises with limited functions and risks should prepare the comparable data and other relevant materials in the year in which a loss occurs, regardless of whether they meet the standards for preparing comparable data. These materials should be submitted to the competent tax authorities by June 20 of the following year.

When assisting enterprises in preparing comparable data, we consider it not only as a compliance obligation but also as a process of reevaluating whether related-party transactions adhere to the arm's length principle. This process is essential not only for effective tax planning and risk management but also for helping enterprises establish a sound business structure and transaction arrangements to mitigate tax risks.