1. According to "Regulations Governing Assessment of Profit-Seeking Enterprise Income Tax on Non-Arm's-Length Transfer Pricing " Article 22 1st paragraph, the transfer pricing report should include:
   1. A comprehensive business overview, including history, main business activities, and analysis of economic and legal factors that affect transfer pricing.
   2. A description of organization structure, including organizational charts of all affiliated companies (if any), register of directors, supervisors and managers and data of change one year before and after the current year.
   3. Summaries of controlled transactions, including types, procedures, dates, objects, quantities, terms of sale, contract clauses and purpose of transactions. The purpose shall include the description for sale or use and its benefits.
   4. The transfer pricing report should include the following content:
      1. Industry and economic circumstance analysis;
      2. Functional and risk analyses of all the participants of the Controlled Transaction. In the event of business restructuring, functional and risk analyses must be submitted to cover both pre-restructuring and post-restructuring;
      3. A description of instance complied by the principle of Article 7;
      4. A description of comparables and relevant data selected by the principle of Article 8;
      5. Comparability analysis based on the principle of Subparagraph 1 of Article 9;
      6. An estimation of whether the allocation of profits in the Controlled Transaction is at arm’s length while the business restructuring is involved, in accordance with Article 9-1;
      7. A description of the selected best method and rationale, and explanation of why alternative methods were not selected;
      8. Transfer Pricing method of related parties for conducting controlled transactions and relevant data; and
      9. The conclusion of measurement of the method selected by the best method rule including the relevant data of comparables and the adjustments made to eliminate the difference prescribed in Subparagraph 1 of Article 9, assumptions used, arm’s length range, the result of the conformation of the arm’s length and the adjustments based upon the results of the arm’s length transactions.
   5. Associated Enterprises Statements and Consolidated Reports of the associated enterprises and other materials as required pursuant to Article 369-12 of the Company Law.
   6. Other documents in relation to related parties or controlled transactions, which may affect pricing,

2. There are no specific restricion on the format of a transfer pricing report as long as it includes all the contents as mentioned above.