On April 2, 2025, the Hwuason team, through close collaboration and representation by attorney Jiang Zhenghe, secured a favorable judgment in an export tax fraud case. The company's principal, accused of defrauding nearly RMB 9 million in tax refunds with no mitigating factors such as voluntary surrender or meritorious conduct, initially faced a potential sentence exceeding 10 years. After a thorough review of the case files, Hwuason's lawyers presented a defense to the procuratorate, arguing that certain transactions did not constitute tax fraud. The procuratorate ultimately accepted the defense, reducing the alleged fraud amount from the figures determined by the tax and public security authorities to approximately RMB 4 million. Accordingly, the procuratorate recommended the minimum statutory sentence of 5 years for the adjusted amount. The People's Court adopted the sentencing recommendation, and the Hwuason team successfully secured a 5-year prison term for the client—an optimal outcome under the circumstances.

China's version of the CRS rules has been implemented for years, and the mechanism of automatic exchange of information on the offshore financial accounts of China's tax residents has helped China's tax authorities to significantly improve their effectiveness in detecting tax evasion on overseas income. In the process of global tax transparency, the tightening of tax regulations has imposed stricter tax compliance requirements on Chinese tax residents with offshore income and assets. This article suggests that HNWIs should pay great attention to the tax compliance of overseas income, proactively comply with the trend of upgrading global tax regulation, and accurately identify and properly deal with the potential risks hidden in overseas financial accounts.

Surplus invoices, as one of the primary sources of invoice-related illegal activities, have persisted for years despite repeated crackdowns. The internet industry, which directly connects a large number of individual consumers and service providers, hosts both supply and demand sides for invoices. Due to the intangible nature of internet products and the concealability of such crimes, the sector has gradually evolved into a new hotspot for surplus invoice fraud. Recently, three high-profile cases involving fraudulent issuance of surplus invoices by online recharge platforms have erupted, involving massive amounts and drawing widespread public attention. For both issuers and recipients of surplus invoices, the unique characteristics of the internet industry introduce tax risks distinct from those in traditional sectors. In this article, the author analyzes the differing circumstances faced by issuers and recipients based on observed patterns and emerging practices in the industry, shedding light on potential tax risks.

On March 28, 2025, the State Administration of Taxation (SAT) issued the Law of the People's Republic of China on Tax Collection and Administration (Revised Draft for Public Consultation) and publicly solicited comments from the public. Ten years since the revision of the Tax Collection and Administration Law was publicly solicited for opinions in 2015, the State has restarted the revision of the Tax Collection and Administration Law, which will surely have a far-reaching impact on the construction of the rule of law in China's taxation. From the perspective of protecting the legitimate rights and interests of taxpayers, regulating tax collection by tax authorities in accordance with the law, and promoting the establishment of a tax collection and payment relationship of equality, mutual trust and cooperation, Hua Shui's legal team, through the interspersed analysis of the current tax collection and administration law, the 2015 revision of the tax collection and administration law and the key provisions of the 2025 public consultation, and combining with its own experience of tax practice, has put forward a number of modification suggestions for some of the important provisions in the revision of the Taxation Collection and Administration Law. The text of the amendments submitted by Hua Shui is now forwarded as follows, and we hope to discuss them with the readers.

Surplus invoices, as one of the primary sources of invoice-related illegal activities, have persisted for years despite repeated crackdowns. The internet industry, which directly connects a large number of individual consumers and service providers, hosts both supply and demand sides for invoices. Due to the intangible nature of internet products and the concealability of such crimes, the sector has gradually evolved into a new hotspot for surplus invoice fraud. Recently, three high-profile cases involving fraudulent issuance of surplus invoices by online recharge platforms have erupted, involving massive amounts and drawing widespread public attention. For both issuers and recipients of surplus invoices, the unique characteristics of the internet industry introduce tax risks distinct from those in traditional sectors. In this article, the author analyzes the differing circumstances faced by issuers and recipients based on observed patterns and emerging practices in the industry, shedding light on potential tax risks.

On July 10, 2012, Company A borrowed RMB 30 million from the bank and signed a mortgage contract, and created a mortgage on several properties in its name. on July 20, 2012, the bank completed the registration of the mortgage and obtained a mortgage certificate. As Company A failed to repay the loan at maturity, the bank filed a lawsuit with the court. on June 10, 2014, the court ruled that Company A should repay the principal amount of the loan and the overdue interest to the bank, and at the same time, confirmed the bank's right to priority compensation for the mortgaged property. After the judgment came into effect, on August 18, 2014, the bank applied to the court for compulsory execution. in July 2020, the claim in question was assigned by a natural person, Li Mou, after two assignments, and the court changed the applicant for execution to Li Mou. from September to October 2024, the mortgaged property was unsuccessfully sold through the first and second auctions. in November 2024, Li Mou applied to the court for a set-off of the debt in kind.

In enterprise bankruptcy proceedings, disputes over the order of satisfaction of tax claims and security claims have long existed. Article 45(1) of the current Tax Administration Law stipulates that if the tax claim arises before the secured claim, the tax claim shall be paid in priority, while the Enterprise Bankruptcy Law clearly stipulates the right of exclusion of the security right, and the secured claim in the bankruptcy procedure enjoys the right of priority within the scope of the realization of the secured property. This article takes a bankruptcy claim confirmation dispute case as a citation and analyzes it from the dimensions of legal application rules and coordination of legal system, which provides clearer rules and guidelines for solving the same kind of disputes.

On March 28, 2025, the State Administration of Taxation (SAT) heavily released the Tax Collection and Administration Law of the People's Republic of China (Revised Exposure Draft) and the Explanation on <The Tax Collection and Administration Law of the People's Republic of China (Revised Exposure Draft)> for public comment.2025 The Tax Collection and Administration Law (Revised Exposure Draft), on the basis of On the basis of "retaining the collection and management system that has been tested and proven in practice for many years" and "maintaining the basic structure of the current tax collection and management law", the 2025 Tax Collection and Management Law (Draft Revision for Public Opinion) is less innovative than the 2015 Tax Collection and Management Law (Draft Revision for Public Opinion), but it still brings many Significant Changes. Huatax lawyers have analyzed the key provisions of the current tax administration law, the 2015 Tax Administration Law (Draft Revision for Public Opinion) and the 2025 Tax Administration Law (Draft Revision for Public Opinion), summarized twenty-one important changes, analyzed the impacts of these changes on both the taxpayers and the taxpayers, and put forward targeted suggestions for revising and perfecting some of the provisions, which are expected to be discussed together with the readers.