This informal review is raising two important issues that are not new for the European Chamber and concern all the Equipment Leasing Companies (ELCs) in the NBFI working group but that had never been problematic so far, i.e., KR 3.2 and KR4 concerning the taxation of ELCs and ELCs’ cross-border guarantees. The Tax Bureau is challenging the ELCs’ thin-cap ratio (also called debt-to-equity ratio) and the reasonableness and necessity to raise fund under guarantee from related party. The Equipment Leasing Companies have agreed to complete a benchmarking exercise to collect relevant information to prepare a report on Equipment Leasing that will be presented to Changning district Tax Bureau. All the collected data will be anonymised and treated confidentially