In January 2026, the Ministry of Finance and the State Taxation Administration issued the Announcement of the Ministry of Finance and the State Taxation Administration on VAT and Consumption Tax Policies for Export Operations (Announcement No. 11 of the Ministry of Finance and the State Taxation Administration [2026]), which largely continues the existing export tax rebate (exemption) system. It replaces the Notice of the Ministry of Finance and the State Taxation Administration on VAT and Consumption Tax Policies for Exported Goods and Services (Cai Shui [2012] No. 39, now invalid) and Annex 4 of the “Notice on Comprehensively Promoting the Pilot Program for Replacing Business Tax with Value-Added Tax” (Cai Shui [2016] No. 36), “Provisions on the Application of Zero-Rated VAT and Exemption Policies for Cross-Border Taxable Activities” (Annex 4 now invalid). It unified the regulation of exported goods, cross-border sales of services, and intangible assets under export operations, significantly enhancing the systematic nature, clarity, and applicability of export tax rebate (exemption) policies. To implement Announcement No. 11 and strengthen export business management, the State Taxation Administration subsequently issued the Announcement of the State Taxation Administration on the Administration Measures for VAT and Consumption Tax Refunds (Exemptions) for Exported Goods and Services (State Taxation Administration Announcement No. 5 of 2026). Announcement No. 5 of 2026 generally retains the existing export tax rebate (exemption) management provisions, consolidates management documents issued at different times, and addresses prominent practical issues and taxpayer concerns. It establishes unified and standardized management measures, providing clear, explicit, and actionable guidance for taxpayers handling export tax rebate (exemption) procedures. In light of this, Huashui plans to adopt a practical approach, incorporating changes in the new policy. Through a series of articles focusing on key export business points and common issues, we will provide detailed analysis on various matters for the foreign trade industry, including documentation filing, disguised self-operations and genuine agency arrangements, input invoices, and foreign exchange receipts, for taxpayers' reference. This article aims to trace the origins of regulations concerning documentation filing and analyze the policy changes and their practical implications.

Editor's Note: Preferential tax policies are an important institutional arrangement for a country to guide industrial development, support market entities, and encourage technological innovation. Accurately understanding and applying relevant preferential policies is both a right of taxpayers and a legal obligation they must fulfill. Recently, the State Administration of Taxation announced four inspection cases involving multiple industries, including pharmaceutical technology, shipbuilding, information technology, and energy. These cases cover major policy types such as the additional deduction for research and development (R&D) expenses, corporate income tax preferences for small low-profit enterprises, and tax reductions and exemptions for small-scale taxpayers. These cases provide specific samples for observing common understanding deviations and operational issues in the actual implementation of tax incentives. This article will analyze the key points that need attention when applying the aforementioned policies based on these cases and discuss possible changes in related tax treatments under the framework of new laws and regulations, such as the 2026 new Value-Added Tax (VAT) regulations.

Editor's Note: Since 2026, more than 20 listed companies have issued announcements on paying back taxes. According to public information, the earliest retrospective adjustment of taxable years can be traced back to 2019, among which there are cases involving the repayment of over 100 million yuan in taxes and late payment fees (interest). This paper focuses on the main causes of tax repayment disclosed by listed companies in recent years, analyzes the high-risk points of key issues, and puts forward tax compliance suggestions for the reference of enterprises in general.

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Editor's Note: On January 23, 2026, the Management Measures for Online Freight Carrier Platform Operations (Transport Regulation [2026] No. 1, hereinafter referred to as the "New Measures") officially came into effect. Compared to the Interim Measures for the Administration of Online Platform Road Freight Transport Operations issued in 2019 (hereinafter referred to as the "Interim Measures"), the New Measures align with the trends of digitalized tax supervision and the construction of a unified national market. They also connect with regulations already implemented in 2025, such as the Provisions on the Reporting of Tax-Related Information by Internet Platform Enterprises (hereinafter referred to as the "Tax Information Reporting Provisions"), collectively establishing a stricter regulatory framework. The New Measures focus on addressing long-standing industry pain points like fraudulent invoicing and non-genuine business by clarifying platform responsibilities, strengthening data sharing, and enabling full-process business traceability. This article will analyze specific changes and impacts by comparing old and new clauses and provide compliance operation recommendations for platforms.

Editor's Note: Editor's Note: In recent years, high-tech enterprises, as core carriers of technological innovation, have enjoyed a range of policy incentives and preferential treatments— including tax reductions and exemptions, R&D subsidies, and talent recruitment support. These policies have become crucial for enterprises to enhance core competitiveness and for local governments to drive industrial upgrading. However, in practice, maintaining high-tech qualifications poses numerous challenges related to Tax Risks for High-Tech Enterprises. Some enterprises fail to conduct comprehensive and continuous evaluations of core indicators for high-tech qualifications or establish effective control mechanisms, ultimately leading to the revocation of their qualifications and corresponding economic losses. Additionally, a handful of enterprises take chances, fraudulently securing preferential tax treatments through illegal means such as fabricating false R&D activities, resulting in serious losses of national tax revenue. Relevant entities may also bear administrative liability for tax violations and even criminal liability. In view of this, this article sorts out common types of high-tech qualification revocation and reveals the associated Tax Risks for High-Tech Enterprises by combining regulatory dynamics of high-tech qualifications and typical tax cases, providing practical references for high-tech enterprises.

Editor's Note: After the implementation of the judicial interpretation on tax-related crimes issued by the Supreme People's Court and the Supreme People's Procuratorate (the "Two Supreme Courts"), the exculpatory provisions for the crime of falsely issuing special VAT invoices have narrowed its scope of crackdown. In contrast, the crime of illegally selling special VAT invoices has shown a significant trend of expanded application. Both judicial data and typical cases have confirmed this tendency, which has also sparked controversies over the application of the crime. This article conducts an argument from two aspects: legislative background and sentencing rules. It traces the historical origin of this crime, which was split off from the crime of speculation and profiteering. Combining with early typical cases and authoritative interpretations, it clarifies that the original legislative intent was to combat the reselling of blank invoices and the infringement of the state monopoly on invoice issuance. In addition, by sorting out the evolution of conviction and sentencing rules from "face value" to "face tax amount", it emphasizes that these concepts are all judicially constructed amounts rather than the actual amount of falsely invoiced tax, further confirming that the object of this crime is limited to blank invoices. In response to the application deviations in judicial practice, the scope of application of this crime urgently needs to be narrowed. On the basis of adhering to the principles of legality of crimes and punishments and adaptation of crime, responsibility, and punishment, reasonable diversion should be achieved through such crimes as the crime of falsely issuing invoices and the crime of tax evasion, so as to maintain the internal coordination of the criminal law system.

Editor's Note: On January 1, 2026, to facilitate the implementation of the Value-Added Tax (VAT) Law and its implementing regulations, the State Taxation Administration promulgated the *Announcement on Relevant Matters Concerning the Registration and Management of General VAT Taxpayers (Announcement No. 2 of 2026)* and its official interpretation. The relevant provisions concerning small-scale taxpayers have been adjusted in areas such as qualification criteria, the timing of status change, and the treatment of tax recovered from audits. These changes are expected to impact entities across multiple industries, including the vast number of micro and small enterprises, individual businesses, and partnerships. This article provides a brief analysis.