Editor's Note: Invoice-based tax administration remains an important means of current tax collection and administration. Measures such as suspending invoice issuance, restricting invoice usage, and reducing invoice quotas directly affect the lifeline of business operations. In practice, many tax authorities, after receiving risk alerts from tax big data systems, adopt "one-size-fits-all" measures to suspend or restrict invoices at the preliminary verification stage, leaving enterprises in a predicament of "being unable to issue invoices, business stagnation, and slow rights protection." In April 2026, the Panjin Intermediate People's Court rendered a final judgment in Case No. (2026) Liao 11 Xing Zhong No. 16, holding that the tax authority's act of reducing an enterprise's invoice credit quota to "zero" during the risk warning period violated statutory procedures and was obviously inappropriate, and ordered revocation according to law. Its judicial reasoning has reference value for enterprise rights protection in similar cases. This article analyzes the case from four aspects: the disputed issues and the court's judicial reasoning, the legal application path and institutional gaps of the court's judicial rules, and the implications for all parties.

Editor’s Note:To further encourage and guide private individual investment and alleviate taxpayers’ difficulties in raising sufficient funds for tax payment, the Ministry of Finance and the State Administration of Taxation jointly issued theNotice on Individual Income Tax Policies Related to Individual Non-Monetary Asset Investment(Caishui [2015] No. 41), which provides that individual income tax arising from non-monetary asset investment shall be paid, and if a lump-sum payment poses hardship, the tax may be paid in installments within five calendar years. If during the installment payment period the taxpayer transfers the equity interest in the investee enterprise and receives cash proceeds, such cash proceeds shall be prioritized for payment of the outstanding tax arising from the non-monetary asset investment. In practice, some tax authorities take the view that once an individual transfers the equity interest in the investee enterprise during the installment period, the installment payment plan must be terminated. This article examines whether such view has a legal basis, through the lens of a case study.

Editor's Note: In the actual operation of private equity funds, transferring unpaid partnership interests to new partners at zero price is a common commercial arrangement. However, such "zero-price transfers" may trigger tax assessment risks. Starting from the legal nature of subscribed but unpaid interests, this article demonstrates that, under the premise that the partnership agreement explicitly stipulates that only partners with paid-in capital enjoy rights and interests, the fair value of subscribed but unpaid interests is zero, and a zero-price transfer has sufficient legitimate reasons; therefore, the tax authority should not levy corporate income tax. Meanwhile, this article sorts out the legal boundaries of the tax authority's assessment power and reminds enterprises of the risk scenarios that need to be vigilant about when conducting such transactions.

Editor's Note: Recently, HuaShui has received a large number of consultations from traditional Chinese medicine (TCM) enterprises. Although the main products of these enterprises vary, covering products such as bezoars, small rice paper plants, and Ganoderma lucidum spores, the tax issues involved are highly consistent. Specifically, these products had previously been enjoying the corporate income tax exemption policy for primary processing of agricultural products. However, these enterprises have recently received notices from tax authorities stating that the relevant product production processes do not qualify as primary processing of agricultural products and do not meet the conditions for policy application. As a result, the enterprises are required to pay back taxes for previous years along with late payment surcharges. Among these enterprises are leading companies in the TCM industry, with the amounts of taxes and surcharges involved often reaching tens of millions or even hundreds of millions of yuan. What exactly does the scope of primary processing of agricultural products include? Can related TCM products enjoy the tax exemption policy? This article aims to explore and analyze these issues.

​​​​​​​Editor’s Note: Recent intensive adjustments to tax incentive policies in sectors such as new energy vehicles, batteries, and medical aesthetics, alongside accelerated phase-outs of local illegal tax rebates, and continued structural tax support for hard-tech fields like integrated circuits and machine tools, mark a clear "retreat" and "advance" in China's tax policy landscape. This dual movement not only reshapes corporate tax expectations but also harbors multiple risks, including retroactive recovery of past benefits and maintenance of qualification status. This article provides practical guidance for enterprises to comply with and benefit from applicable tax incentives by analyzing the policy logic, risk focal points, and compliance pathways.

Editor's Note: Splitting the income of a single business operation among multiple affiliated small entities so that each separately qualifies as a small and low-profit enterprise and enjoys a lower tax rate has become a common way of breaking up a business to claim tax preferences in recent years. Taking as its starting point a case involving a chain automotive service brand that split store income to claim enterprise income tax benefits, this article applies the 'reasonable commercial purpose' criteria set out by the State Taxation Administration in its Questions and Answers on Issues Concerning Micro and Small Enterprises Improperly Claiming Tax Preferential Policies. It examines whether additional tax should be assessed, whether the conduct may be characterized as tax evasion, and what compliance measures businesses should take when establishing separate entities, with a view to providing guidance for relevant market participants.

Editor’s Note:Since the beginning of 2026, the consumption tax administration rules applicable to beer and baijiu have been adjusted in succession, while several listed alcoholic beverage companies have disclosed substantial back-tax payments. Against the backdrop of continued industry restructuring, the ongoing transformation of sales channels, and increasingly refined tax administration, tax risks facing alcoholic beverage companies are extending beyond individual taxes and isolated business activities to the entire course of their operations. Taking the 2026 changes to the consumption tax administration rules and the back-tax disclosures of listed companies as its starting point, this article draws on tax administration practices across different regions to examine the principal tax risks arising throughout the alcohol industry value chain and offers corresponding recommendations for tax compliance.

Editor's Note: On March 20, 2024, the Interpretation on Several Issues Concerning the Application of Law in Handling Criminal Cases Endangering Tax Collection and Administration officially came into effect. This judicial interpretation made comprehensive adjustments to the threshold for conviction, types of methods, and attempted crime determination for the crime of fraudulently obtaining export tax refunds. This article systematically reviews 27 publicly disclosed cases related to export tax refund fraud from January to August 2026, covering effective criminal judgments, guiding cases from the Supreme People's Court, procuratorial prosecution documents, tax audit transfer reports, and typical cases from the Ministry of Public Security, examining criminal methods and defense strategies from judicial practice.