For a long time, some local governments have been granting partnership enterprises the approved levy policy as a condition for attracting investments, and many investors have enjoyed the policy dividend of low tax burden through equity transfer and other premium transactions through partnership enterprise shareholding platforms. The Announcement on the Administration of Collection of Individual Income Tax on Income from Equity Investment and Operation (Announcement No. 41 of 2021 by the Ministry of Finance and the State Administration of Taxation) stipulates that partnerships with shareholding platforms are subject to individual tax in accordance with the method of account-checking levy, which effectively curbed this kind of tax avoidance operation. Recently, some investors have been notified by the tax authorities in their place of residence that they have been investigated and asked to pay back taxes and penalties in respect of the authorized collection of partnership share transfers in a foreign place several years ago. Whether the authorized tax payment for partnership equity transfer is necessarily illegal, whether the tax authority of the investor's place of residence has the right to investigate and deal with the matter retrospectively, and how the investor should properly deal with such risks? This article analyzes the above practical issues.

In March 2022, the Cyberspace Administration of China, the State Taxation Administration, and the State Administration for Market Regulation jointly issued the "Opinions on Further Regulating Profit-Making Activities in Live Streaming to Promote Healthy Industry Development" (STA Income Tax Notice [2022] No. 25), which explicitly states that "intermediary agencies and related personnel who plan or assist live streamers in illegal tax evasion activities shall be severely punished and publicly exposed." Recently, a major tax-related case involving an MCN agency colluding with illegal intermediaries was reported by CCTV. According to the disclosure, the case involves numerous parties and highly typical tax evasion methods. This article will use this case as a starting point to analyze the causes behind such phenomena in light of current tax administration practices, while clarifying the responsibilities and legal consequences for all parties involved, for the benefit of readers.

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.