China
— The State Administration of Taxation (SAT) launched the
“Thousand Enterprises Initiative” (TEI) in July 2015. This
program covers approximately 1,000 representative large
group enterprises from different industries. Under this
initiative the SAT collects data from the TEI-covered group
enterprises and their member entities (through local tax
authorities) for tax risk analysis. Based on the analysis, the
SAT has built risk analysis models with risk indicators for
different industries.
— Circular Shuizongfa [2014] No. 105 SAT Opinion On
Strengthening Tax Risk Management sets out key tax
risk management tasks for tax authorities. These include
tax enforcement goal setting, information collection, risk
identification, risk ranking and risk resolution, as well as risk
management process monitoring, assessment and feedback.
— The SAT on 18 April 2017 issued SAT Announcement
[2017] No. 10 (Announcement No. 10), which provides
taxpayers with the option of being assisted (through
an automated solution) in identifying and correcting tax
calculation errors, in advance of formally submitting their
CIT annual filing returns. As Announcement No. 10 makes
clear, this automated solution draws attention to potential
issues in tax calculations, non-correlation between tax
data and financial data, and other analytical results that
might prompt a taxpayer to reconsider their original
inputs. The information on which the analysis is based is
drawn from a variety of sources, including taxpayer tax
registration, historic tax filings, financial and accounting
data, record filings, and third party and industry data.
— SAT Announcement [2016] No. 67 on The Filing of Financial
Statements Upon Submission of Tax Returns for “1,000
Group Enterprises” And Their Member Entities was
published on 26 October 2016 and took effect from
1 December 2016. This requires TEI enterprises to file
financial statement information with the tax authorities,
both at the time of filing periodic tax returns during the
year (i.e. quarterly), and with the filing of the annual tax
return (i.e. filed each May following tax assessment year-
end). Financial statements (to be supplied in electronic
form) include balance sheets, income statements,
statements of equity changes, and their disclosure notes,
for every legal entity in a corporate group in China.
— SAT Announcement [2017] No. 7 on The Management
Measures on The “1,000 Group Enterprises” Catalogues
took effect from 1 May 2017. This requires TEI enterprises
to report certain entity information to the tax authorities on
an annual basis (i.e. each May), which will be maintained
on a data platform. This includes details of the taxpayer’s
in-charge tax bureaus, operating locations, industries of
activity, parent company, tax payments in prior years,
revenue in prior years and listed status.
— The Golden Tax System Phase III provides for the
centralized collection of national tax data from all
taxpayers registered with the thousands of individual tax
bureaus at all levels of government across the country.
This covers both local tax bureaus (LTBs — responsible for
local government taxes) as well as state tax bureaus
(STBs — responsible for central government taxes).
The Golden Tax System Phase III aggregates data from
all taxpayer-authority interactions, including tax and
incentive filings, tax payments, tax audits/enquiries,
records of outbound payments from China, tax invoice
issuance/certification and information from reviews
of taxpayer internal tax controls. This is taken together
with webcrawler/public website searches on taxpayers,
industry profiling information used to assess tax risks,
information obtained from overseas tax authorities,
and from other domestic agencies, such as the foreign
exchange control regulator (SAFE — State Administration
of Foreign Exchange) and the commerce ministry
(MOFCOM — Ministry of Commerce). Tax officials in
different tax bureaus across China can tap into this
system, to see prior interactions that taxpayers may have
had with tax and other governmental authorities.
— Under the forthcoming new Tax Collection and
Administration (TCA) Law, Chinese financial intermediaries
will be required to bulk report client account transactions
(exceeding a certain minimum value) to the tax authorities
together with the relevant clients’ tax identification
numbers (TINs) to facilitate data matching (e.g. cross-
checking of IIT filings), and risk ‘red flagging’.
— SAT Announcement [2017] No. 14 on Administrative
Measures on Due Diligence Checks on Tax-related
Information of Non-residents’ Financial Accounts was
published on 9 May 2017, and took effect on 1 July 2017.
This provides the detailed rules under which China is
rolling out the OECD’s Common Reporting Standard (CRS)
for the automatic exchange of tax information. Financial
institutions with operations in China were required to
register on the SAT CRS web platform by
31 December 2017, and then report to the SAT tax
information on the accounts of non-residents held with
their institutions (including tax ID, balance and receipt of
different income types) by 31 May every year (starting
May 2018).
— Since 2016 the Golden Tax System has provided a powerful
platform for pooling tax data from all levels of tax bureaus
across China, covering both central government and local
taxes. Its user interfaces facilitate both taxpayer and tax
authority engagement and input, and drive standardization
of certain key data inputs. The upgraded system also
requires taxpayers to input “goods or service codes”
so that the authorities obtain standardized data on what
goods or services have been covered by the invoices. This
facilitates the tax authorities to closely monitor invoice
creation to detect fictitious invoices, ensuring the integrity
of invoice information and the authenticity of filing data.
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© 2018 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated. © 2018 KPMG International Cooperative (“KPMG International”). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.