Editor's Note: It has been more than a year since the implementation of the "reverse invoicing" policy in April 2024. This year, the National Development and Reform Commission and the Ministry of Finance issued a document to explicitly accelerate the implementation of "reverse invoicing" for resource recycling enterprises to natural person sellers. Since the introduction of the "reverse invoicing" policy, tax authorities in many places have adopted many measures to further improve the tax supervision of resource recycling enterprises and natural person sellers, standardize the tax order of resource recycling industry, and better help the development of circular economy. Based on the recent tax-related trends in the field of renewable resources, this paper analyzes the tax supervision situation faced by resource recycling enterprises and natural person sellers, and prompts the key points of tax compliance for readers' reference.

Editor's note: The current Interim Regulations on Value-Added Tax do not explicitly stipulate the attribute of VAT as a tax excluded from the price, but relevant rules support the operation mode of such a tax. However, in some buyer's markets, the parties to a transaction may agree that the seller shall bear the VAT, that is, adjust the tax excluded from the price to a tax included in the price through the contract. China's VAT Law will come into effect on January 1, 2026, which clarifies the attribute of VAT as a tax excluded from the price in the form of law. After the implementation of the new law, whether the parties to a transaction can still adjust the tax excluded from the price to a tax included in the price through contractual agreements, what tax risks such agreements will bury, and how to timely adjust the provisions of contract clauses, these issues require market entities to pay attention.

Editor's note: Since the beginning of this year, there have been frequent tax risks such as false invoicing and tax evasion by CSO companies in the pharmaceutical field. The government has also issued normative documents related to CSO companies, such as the "Measures for the Administration of Pharmaceutical Representatives," which demonstrates the increased supervision of CSO companies by the government. As the country strengthens the regulation of CSO companies, non-compliant CSO companies will face more tax risks. Based on this, this article will discuss the administrative and criminal risks faced by CSO companies, and propose corresponding measures to deal with the tax risks faced by CSO companies, combined with the recent specific cases and relevant laws and regulations.

Editor's note: the national unified market is an important pillar indispensable to the construction of the new development pattern of the double cycle, 2022 ‘the CPC Central Committee State Council on accelerating the construction of the national unified market of the opinion’ put forward to ‘accelerate the clean-up and abolition of various regulations and practices that impede the unified market and fair competition’, ‘improve the fair competition review system’. improve the fair competition review system". With the implementation of the ‘Fair Competition Review Regulations’ and its implementation rules, the financial incentives and subsidies given by local governments in the process of attracting investments in the past have faced questions about their legitimacy and have been gradually cleaned up. Some special industries rely heavily on such local policies, and once they lose the incentives and subsidies, they cannot operate. For example, some with social welfare nature of the business, such as the recycling of low-value resources, this is not profitable, without government subsidies, private enterprises will not participate. Another example is the network freight transport discussed in this paper, which has to rely on incentives and subsidies to survive because of the inherently heavy tax burden. With the abolition of local policies, the national unified market background of the network freight industry will go?

Editor's note: the national unified market is an important pillar indispensable to the construction of the new development pattern of the double cycle, 2022 ‘the CPC Central Committee State Council on accelerating the construction of the national unified market of the opinion’ put forward to ‘accelerate the clean-up and abolition of various regulations and practices that impede the unified market and fair competition’, ‘improve the fair competition review system’. improve the fair competition review system". With the implementation of the ‘Fair Competition Review Regulations’ and its implementation rules, the financial incentives and subsidies given by local governments in the process of attracting investments in the past have faced questions about their legitimacy and have been gradually cleaned up. Some special industries rely heavily on such local policies, and once they lose the incentives and subsidies, they cannot operate. For example, some with social welfare nature of the business, such as the recycling of low-value resources, this is not profitable, without government subsidies, private enterprises will not participate. Another example is the network freight transport discussed in this paper, which has to rely on incentives and subsidies to survive because of the inherently heavy tax burden. With the abolition of local policies, the national unified market background of the network freight industry will go?

Editor's Note: On June 20, the State Council's ‘Regulations on Tax-Related Information Reporting by Internet Platform Enterprises’ was announced and came into effect, providing a clear definition of ‘Internet platform enterprises’, ‘e-commerce platform operators’ and ‘other organisations providing network business premises, transaction aggregation, information dissemination and other profit-making services for network trading activities’. The ‘e-commerce platform operator’ and ‘other organisations providing network business premises, transaction aggregation, information dissemination and other for-profit services for network trading activities’ are included, especially the latter with a broader scope. However, some emerging businesses are still controversial as to whether they are ‘Internet platform enterprises’. On 30 June, the State Administration of Taxation (SAT) issued the Announcement on Matters Relating to the Reporting of Tax-Related Information by Internet Platform Enterprises (No. 15 of 2025) and the Announcement on Matters Relating to the Reporting of Tax-Related Information by Internet Platform Enterprises (No. 16 of 2025), and Announcement No. 15 explicitly lists seven types of enterprises as belonging to the scope of ‘Internet platform enterprises’. "The controversy has been settled. Among them, flexible labour platforms are listed. Circular No. 15 makes detailed provisions on the scope, content, time and manner of reporting tax-related information by Internet platform enterprises and the handling of failure to report in accordance with the regulations, while Circular No. 16 focuses on the scenarios of employees obtaining labour remuneration or service income from Internet platform enterprises, optimises the withholding and prepayment method of personal tax on income from labour remuneration, and refines the relevant provisions on the declaration of value-added tax (VAT) and surcharge on behalf of the employees. Against this background, flexible labour platforms are facing profound changes, and the industry may face a ‘reshuffle’.

Editor's Note: In the field of renewable resources, coal and other bulk trade, road transport is one of the main modes of transport, and thus the authenticity, accuracy and completeness of transport information play an important role in the determination of the authenticity of the business of purchase and sale. In practice, due to the inconsistency between the transport information and the real business in the purchase and sale business, a large number of cases in which the authenticity of the enterprise's business has been denied and thus characterised as false opening or tax evasion. Then, the enterprise should be how to achieve the form and substance of transport information compliance, this article will be briefly analysed in conjunction with the case.

Editor's note: Recently, many local tax bureaus have investigated and dealt with multiple cases of tax intermediaries. Tax intermediaries engage in tax planning through illegal methods such as concealing income and issuing false invoices. The 2024 China Tax Annual Report released by the State Administration of Taxation clearly pointed out the need to strengthen supervision of tax-related professional service agencies and enhance comprehensive governance of illegal and irregular behaviors of tax-related intermediaries. It can be seen that the state maintains a high-pressure situation on the illegal and irregular behavior of tax-related intermediaries, and the regulatory efforts have not decreased at all. Therefore, for practitioners in this industry, it is urgent to regulate their professional behavior and strengthen tax compliance. Based on this, this article will combine some cases to analyze the tax risks faced by tax intermediaries.