In order to cope with the shortage of cash flow to postpone the fulfillment of debts, or to successfully raise funds, real estate development enterprises may choose to use the commercial properties they have developed to enter into a sale and purchase contract with creditors, and adopt the method of granting guarantees to guarantee the fulfillment of debts. Although the transfer guarantee is not intended to be a transfer of real estate, if a change in property ownership occurs during the transfer guarantee process, there is a risk that the tax authorities will recognize it as a transfer of real estate and levy a land value-added tax (LVAT) on it.

High-income people's equity transactions are characterized by large amount of subject matter and complex commercial arrangements, etc. Under the background of "double random, one open" normalized tax supervision, their equity transfer has become the focus of tax audit. In the complex business background, the existing tax policy has a certain lag, the practice of equity transfer tax-related disputes are endless, in the background of strict regulation of high-income people's equity transactions there are a lot of tax-related risks, this paper to the practice of equity transfer of the five common types of tax-related risks as an entry point for discussion, for reference.
In March 2021, the General Office of the Central Committee of the Communist Party of China (CPC) and the General Office of the State Council issued the Opinions on Further Deepening the Reform of Tax Levy and Administration, which explicitly pointed out to strengthen the tax service and supervision of high-income and high-net-worth individuals in accordance with the law. The Inspection Bureau of the State Administration of Taxation subsequently issued a document stating that it would strengthen the supervision of high-income earners in key areas such as equity transfers. The Measures for Administration of Individual Income Tax on Income from Equity Transfer (for Trial Implementation) (SAT Announcement No. 67 of 2014, hereinafter referred to as "Announcement No. 67") is the main policy basis for the tax-related treatment of individual equity transfers at present, and provides regulations on individual equity transfers in terms of income from equity transfers, recognition of the original value of the equity shares, and management of tax declarations, etc. Announcement No. 67 is the main policy basis for the tax-related treatment of individual equity transfers. Circular 67 is a general provision on the transfer of equity interests by natural persons, but under the complex commercial arrangements in practice, the application of income tax on equity transfers in some cases is highly controversial, which may expose high-income earners to administrative or criminal risks.

Fraudulent export tax refunds have always been a key target of the fight because they cause huge losses to the country's tax money and jeopardize the order of export tax administration. At the same time, the administrative and criminal liability for fraudulent export tax rebates is also extremely heavy. In the light of the suspension of the right to export tax refunds, payment of taxes, late fees, fines, or face criminal liability of up to life imprisonment. In order to better strengthen the majority of foreign trade industry enterprise compliance, to prevent problems before they occur, this paper examines the State Administration of Taxation since 2022 publicized cases of fraudulent export tax refunds, the reasons for the outbreak of the case, the trigger to be summarized for the reader's reference.

Due to the late establishment of China's modern tax law system, a large number of enterprises, especially private enterprises, lack the necessary understanding of tax compliance, so tax-related crimes have also become a "roadblock" that impedes the development of private enterprises, and many entities have been sentenced to criminal penalties for suspected tax evasion and fraudulent invoicing.2022 Since April 22, the compliance reform for case-related enterprises led by the Supreme People's Procuratorate has been rolled out nationwide and has achieved good results in practice. Since April 2022, compliance reforms led by the Supreme People's Procuratorate for enterprises involved in tax evasion have been rolled out nationwide and have achieved good results in practice. By handling a number of cases involving compliance reforms, we have noticed that the previous compliance reforms led by the procuratorate had some problems in practice due to the lack of court involvement:
1. Procuratorial authorities only have a single way of closing cases with "relative non-prosecution", and do not easily carry out compliance reforms for felonies that may be sentenced to more than 10 years of imprisonment. Due to the high penalty for the crime of false VAT invoicing, it is impossible to carry out compliance, which is not conducive to saving the real enterprises.
2. The period of review and prosecution stage by the procuratorial authorities is too short, and there are cases in which the enterprises involved in the case did not file compliance applications in time, or the enterprises could not complete the rectification within the period, so they can only resort to the court in the end.
3. At the trial stage, the court lacks a policy basis for applying to the enterprise's willingness to file a compliance rectification application, and to the sentencing recommendation of the prosecuting authority based on the compliance rectification circumstance that breaks the statutory sentence or suspended sentence.
At present, the extension of criminal compliance to the trial stage will strive to solve the above problems, which is conducive to saving the real enterprises. In practice, courts have already issued "exemption from criminal punishment" sentences through compliance at the trial stage. It should be noted that there are some unique problems for enterprises in tax-related crimes, which need to be further refined in the reform. This paper first summarizes and analyzes the current pilot policy, and then interprets the current pilot from the perspective of how court involvement in compliance differs from that of the prosecutor's office.

The change of "limited liability company" to "partnership" is a common structural arrangement for enterprises to implement equity incentives and build employee shareholding platform. Since November 2022, tax authorities in many places have been checking the failure to liquidate the "company to partnership" process. Recently, the news that an internet financial data service company faced a huge amount of back tax due to the failure to liquidate the tax in the change of organization form of its shareholding platform triggered the heated discussion on the compliance issue of "company to partnership" once again. The recent news of an Internet financial data service company facing a huge tax reimbursement for failing to clear the tax in the organizational form of its shareholding platform has once again triggered a heated debate on the compliance issue of "company to partnership". Does "company to partnership" require liquidation in business and taxation, and does the tax authority have the right to recover the unpaid tax in the process of change of organization form, and from whom should the tax authority recover the tax? This article will discuss and analyze the above issues for reference.

According to the provisions of the Criminal Law and relevant judicial interpretations, false invoicing of VAT includes four modes of behavior: false invoicing for others, false invoicing for oneself, letting others false invoicing for oneself, and introducing others to false invoicing. However, in specific cases, are the invoicing party and the invoiced party necessarily guilty of the same crime? Why some cases in the invoicing party constitutes false opening, but the invoiced party does not constitute false opening? This article discusses the responsibility determination of different subjects in the behavior of false invoicing of VAT special purpose invoices through two corresponding cases of the invoicing party and the invoiced party, as well as how to prevent the risk of false invoicing in the daily transactions of the invoiced enterprises in practice for the readers' reference.

In recent years, the regulation of personal income tax has continued to generate heated discussions, and has gradually developed into a troika of VAT, corporate tax and personal tax. Among them, the personal income tax of high net worth individuals has become a key concern of the state. HNWIs are under heavy tax pressure and have sufficient resources to assist them in tax planning, but in a time of tightening regulations, such "planning" may lead to huge tax risks. The purpose of this article is to shed light on the tax risks that HNWIs may be exposed to, for the benefit of the readers.

Since the refined oil invoice module went online, the petrochemical industry has quietly transformed its tax-related cases and tax risks, and the risks associated with the new variable invoice model will affect the entire industry chain. Recently, a case of false invoicing by means of hacking technology was sentenced, and the main culprit was sentenced to 12 years' imprisonment. This paper is intended to analyze the current risks in the petrochemical industry in the light of the case, and put forward a few suggestions for prevention and response, so that enterprises can control the tax-related risks at an acceptable level.