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China’s First Cross-Border Tax Industry Guide: International Transport Compliance Roadmap

The State Taxation Administration released China’s first industry-specific cross-border tax guide on 31 July 2026, dedicated to international transport. 国家税务总局于 2026 年 7 月 31 日发布首个专门针对跨境运输的税收行业类指引。 The guide is split into an “inbound” volume and an “outbound” volume, distinguishing maritime, … China’s First Cross-Border Tax Industry Guide: International Transport Compliance RoadmapRead more

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Related-Party Disclosure and Contemporaneous Documentation for Foreign-Invested Enterprises (2026)

Any FIE that has related-party transactions, or meets the country-by-country reporting test, must file the annual related-party transaction return (the “Associated Party Business Reporting Form”) by 31 May. 凡是存在关联交易或符合国别报告条件的外商投资企业,均须于5月31日前报送年度关联业务往来报告表(关联申报)。 Three contemporaneous-documentation files — master file, local file, and specified-matters file … Related-Party Disclosure and Contemporaneous Documentation for Foreign-Invested Enterprises (2026)Read more

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Corporate Tax Residency and CFC Rules for Foreign-Invested Enterprises in China (2026)

A company incorporated in China, or incorporated abroad but effectively managed in China, is a Chinese tax resident and is taxed on its worldwide income, not merely its China-source income. 在中国境内成立,或在境外成立但实际管理机构在中国境内的企业,为中国税收居民,就全球所得纳税,而非仅就中国境内所得纳税。 The “place of effective management” test looks at where … Corporate Tax Residency and CFC Rules for Foreign-Invested Enterprises in China (2026)Read more

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Tax Inspection and Voluntary Disclosure for Foreign-Invested Enterprises in China: Handling a SAT Audit and Self-Correction

A tax inspection of a foreign-invested enterprise usually begins with a “double-random, one-open” (双随机、一公开) selection, not a tip-off. 外资企业的税务稽查通常始于”双随机、一公开”的抽查选案,而非举报。 Self-correction before the focused inspection is the cheapest exit: truthful disclosure, voluntary back-payment of tax and late fees draws mitigated, reduced … Tax Inspection and Voluntary Disclosure for Foreign-Invested Enterprises in China: Handling a SAT Audit and Self-CorrectionRead more

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Tax Residency for Foreign Individuals in China: The 183-Day Test, the Six-Year Rule and Treaty Relief

In China, tax residency turns on domicile or an aggregate 183-day stay in a tax year; a resident is taxed on worldwide income, a non-resident only on China-source income. 在中国,税收居民身份取决于住所或一个纳税年度内累计 183 天的居住;居民就境内外所得纳税,非居民仅就境内所得纳税。 “Domicile” means habitual residence from household, family or … Tax Residency for Foreign Individuals in China: The 183-Day Test, the Six-Year Rule and Treaty ReliefRead more

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Transfer pricing rules for FIEs

China’s transfer pricing rests on the arm’s-length principle (EIT Law Art. 41); authorities may adjust prices departing from independent-party benchmarks and charge back-tax plus interest. 中国转让定价以独立交易原则为基础(企业所得税法第四十一条);对偏离独立方基准的定价可作调整并补税加收利息。 Every qualifying enterprise must file the Annual Associated-Party Transaction Reporting Form with its CIT … Transfer pricing rules for FIEsRead more

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Tax treaty benefits for foreign investors

As of 2025, China’s tax-treaty network covers 114 countries and regions — including 90 Belt and Road partners — among the largest in the world. 截至 2025 年,中国税收协定网络已覆盖 114 个国家和地区(含 90 个共建”一带一路”伙伴),居世界前列。 A treaty reduces the 10% domestic WHT: a … Tax treaty benefits for foreign investorsRead more

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Tax Deregistration and the Tax Clearance Certificate for FIEs Exiting China: Liquidation Income Filing, Instant Processing and the Commitment-Based Tolerance Channel

The tax clearance certificate (清税证明) is the real gatekeeper of an FIE exit: without it the market regulator will not deregister the business licence. 《清税证明》才是外资企业退出的真正关口:没有它,市场监管部门不会办理营业执照注销登记。 Two categories of taxpayer are exempt from the certificate altogether and may go straight to … Tax Deregistration and the Tax Clearance Certificate for FIEs Exiting China: Liquidation Income Filing, Instant Processing and the Commitment-Based Tolerance ChannelRead more