Editor's Note: Recently, A-share listed companies have intensively disclosed tax repayment announcements, drawing high attention from the capital market. According to incomplete statistics, as of the end of April, nearly 60 listed companies had issued tax repayment announcements with a total tax repayment amount exceeding 3.5 billion yuan. The concentrated tax repayment by listed companies is not an isolated occasional tax-related incident, but a combined outcome of the implementation of new tax collection and administration policies, intensified normalized supervision, and accumulated historical tax-related risks of enterprises. Based on the public tax repayment announcements of listed companies, this paper analyzes from four dimensions: typical case studies, tax supervision environment, main manifestations of tax-related risks, and tax compliance management suggestions, to provide references for all market participants to strengthen tax compliance management.

 

I. Analysis of Typical Cases of Concentrated Tax Repayment by Listed Companies

1.1 Significant Differentiation in Tax Repayment Amounts, Large-Scale Tax Repayments Concentrated in Key Industries

Nearly 60 listed companies have repaid a total of over 3.5 billion yuan in taxes, with a striking divergence in single-instance tax repayment amounts. Enterprises including Guanghui Energy and its subsidiaries, ST Juewei, Haidewei Bio, a subsidiary of Taiji Industrial, and Minmetals Capital and its subsidiaries each repaid more than 200 million yuan in a single case; nine announcements (covering Huaihe Energy and its subsidiaries, Bluestar Medical and its subsidiaries, a subsidiary of Guansheng Stock, a subsidiary of Shouxian Gu Valley, etc.) account for nearly 60% of the total tax repayment sum.

Capital-intensive industries such as energy, chemical engineering, and high-end manufacturing are prone to cross-year large-scale retroactive tax repayments once subject to tax verification, due to their large historical investment scale, diverse tax types involved, and complex policy application. With the normalized liquidation of land appreciation tax, full implementation of environmental protection tax collection, and continuous deepening of resource tax reform, historical legacy tax risks of such enterprises have been intensively exposed. Enterprise management shall establish full-life cycle tax management ledgers for long-term assets and major projects to realize full-process traceability and dynamic control of tax-related matters.

 

1.2 Non-Compliant Application of Tax Preferences, High Incidence of Tax Recovery Cases

Ineligibility for three core tax preferences—high-tech enterprise incentives, western development preferences, and comprehensive resource utilization incentives—has become the primary cause of tax repayments for listed companies, involving over 10 enterprises and more than 500 million yuan. Specifically:

A subsidiary of Taiji Industrial (11th Science and Technology) was required to repay 253 million yuan in corporate income tax for 2020–2024 due to non-compliance of partial businesses with high-tech enterprise qualification criteria;

Seven subsidiaries of Chongqing Pharmaceutical Holdings were deemed ineligible for western development tax preferences;

A subsidiary of Luyang Energy-Saving repaid over 58 million yuan in taxes for failing to meet the VAT refund-on-collection qualification for comprehensive resource utilization.

Such enterprises commonly hold the misconception that tax preference qualifications are permanently valid once granted. With the full launch of the Golden Tax Phase IV Project, core indicators (R&D expense ratio, high-tech product income ratio, matching degree with regional industrial catalogs) are subject to real-time cross-departmental verification, and tax preference qualifications have essentially entered a phase of annual review and dynamic adjustment. Enterprises must establish a normalized evaluation, dynamic review, and exit mechanism for tax preference qualifications to eliminate over-range or non-compliant enjoyment of policy benefits.

 

1.3 Shortcomings in Invoice Chain Management, Concentrated Voucher Compliance Risks

Six listed companies explicitly disclosed invoice-related tax issues, including false invoicing, non-compliant input tax deduction, and recovery of export tax rebates:

Oriental International Venture was ordered to repay export tax rebates and pay taxes equivalent to domestic sales (over 40 million yuan) due to false invoices from upstream suppliers;

A subsidiary of Fenglin Group was recovered nearly 40 million yuan in taxes for failing to strictly implement the verified deduction policy for agricultural product input taxes;

A subsidiary of Binhai TEDA Logistics was identified as tax evasion by tax authorities for obtaining false invoices.

These enterprises generally neglected pre-compliance review of supplier invoices. The core logic of **tax governance by data** under Golden Tax Phase IV is real-time aggregation and intelligent comparison of invoice data, which accurately identifies hidden risks such as false invoicing and abnormal deductions. Enterprises must embed invoice compliance review into the full business process (procurement contracting, material warehousing, payment, invoice recording), establish a dynamic database of supplier compliance whitelists and dishonesty blacklists, and prevent invoice and voucher risks from the source.

 

II. Overall Tightening of the Tax Supervision Environment for Listed Companies

2.1 In-Depth Implementation of Golden Tax Phase IV, Full Cross-Departmental Data Connectivity for Tax Governance by Data

The Golden Tax Phase IV Project entered full substantive application in 2026, realizing full data interconnection between taxation, banking, market regulation, customs, social security, and other departments. Penetrating supervision over the entire chain of **capital flow, invoice flow, business flow, and contract flow** has been fully implemented. On April 16, 2026, eight national authorities held a promotion meeting for normalized joint crackdown on tax-related crimes, targeting prominent irregularities such as false "invoicing economy", fake flexible employment, and abnormal cross-border capital flows.

The transparency and traceability of enterprise tax data have been greatly enhanced, sharply reducing the space for tax planning relying on traditional "information barriers". Large transactions, tax preference enjoyment, and cross-border capital receipts/payments of listed companies are all under real-time dynamic supervision. Tax compliance management must shift from passive post-event response to proactive prevention embedded in the entire business process in advance.

 

 2.2 Official Implementation of the *VAT Law*, Tax Statutoryism Compressing Flexible Policy Application Space

The *VAT Law* and its implementing regulations came into force on January 1, 2026, marking that China’s VAT collection and administration has fully entered a new era of tax statutoryism. The law imposes rigid constraints on tax rate application, input deduction scope, and tax preference eligibility, largely eliminating policy gray areas formed by previous departmental normative documents and local enforcement calibers.

CEC Port and its subsidiaries repaid over 57 million yuan in taxes and late fees for "partial business activities failing to meet tax preference conditions", a typical case of policy enforcement shifting from loose interpretation to strict statutory compliance. As all substantive tax types are gradually legislated, the certainty and stability of tax policies have improved significantly, while the compliance and retroactive risks of tax arrangements exploiting policy ambiguities have risen sharply.

 

 2.3 Tax Verification Shifts from Random Inspection to Precise Targeting, High-Risk Entities Under Normalized Monitoring

Leveraging AI risk control models, Golden Tax Phase IV has greatly improved the ability to block abnormal invoices and detect hidden tax risks. The 2026 Tax "Foundation Strengthening Project" institutionalizes and normalizes cross-departmental data sharing, expanding the scope, timeliness, and standardization of external data accessible to tax authorities.

The frequent phrase "upon self-inspection" in listed companies’ announcements essentially means tax authorities push risk clues to enterprises via big data screening and urge self-inspection and rectification. Going forward, tax verification will adopt precise targeted pushing based on risk profiling. The level of tax-related risk indicators directly determines the probability of being inspected; low-compliance enterprises are prone to a vicious cycle of self-tax repayment, performance damage, and reputational pressure.

 

III. Core Manifestations of Tax-Related Risks for Listed Companies

3.1 Regulatory Review Shifts from Formal Compliance to Substantive Compliance, Four-Flow Penetrating Verification Becomes Norm

Frequent invoice risks (false invoicing, input deduction violations, export tax rebate recovery) stem from enterprises’ overemphasis on formal invoice compliance and neglect of substantive matching verification of transaction background, goods delivery, fund payment, and contract terms. Tax authorities now review the entire business chain instead of single invoices.

Enterprises must improve document retention in contract signing, goods acceptance, fund payment, and invoice acquisition to ensure consistency between transaction substance and voucher records, avoiding joint tax liabilities caused by upstream supplier violations.

 

 3.2 Tightened Collection of Specific Taxes, Environmental Protection Tax & Land Appreciation Tax Shift from Soft to Rigid Enforcement

Environmental protection tax and land appreciation tax have emerged as new triggers of tax risks for listed companies, involving 5 enterprises and over 700 million yuan in total repayments:

Huaihe Energy and its subsidiaries repaid 170 million yuan for environmental protection tax issues;

A subsidiary of Shanghai Chengtou Holdings repaid over 90 million yuan for land appreciation tax liquidation;

A subsidiary of Guanghui Energy repaid 960 million yuan in soil and water conservation fees;

Maoye Commercial repaid over 60 million yuan for land appreciation tax liquidation differences.

These taxes feature complex calculation rules, numerous historical projects, and flexible past enforcement. Many enterprises long held the fluke mentality of "no declaration without inspection, no repayment without audit". With the advancement of ecological civilization legislation and natural resource tax administration, the enforcement intensity, retroactive period, and penalty severity of environmental protection tax, land appreciation tax, etc., have all increased. Large tax repayments and late fees will exert a dual impact on enterprises’ net profit and operating cash flow.

 

3.3 High Late Fee Amounts, Evolving from Incidental Costs to Independent Financial Risks

Late fees account for an average of 20% of total tax repayments in disclosed cases:

A subsidiary of Shouxian Gu Valley repaid over 80 million yuan in taxes + 30 million yuan in late fees;

Wanfang Town Investment repaid over 30 million yuan in late fees (taxes settled in 2025);

A subsidiary of Luyang Energy-Saving repaid 36 million yuan in taxes + over 20 million yuan in late fees.

Late fees have become a standalone major financial expense and performance risk. Cross-year non-compliant preference enjoyment and long-term tax arrears will lead to cumulative high late fee burdens.

 

IV. Tax Compliance Management Suggestions for Listed Companies

4.1 Prepose Compliance Risk Control to Prevent Risks at the Source

In response to the strict supervision trend of Golden Tax Phase IV (tax governance by data) and tax statutoryism, listed companies shall embed tax compliance into the entire business decision-making process and conduct normalized pre-risk screening:

Abandon the misconception of "permanent tax preference qualifications"; establish dynamic evaluation and annual review mechanisms for preferences, self-inspect core elements (business substance, income composition, expense allocation) against regulatory indicators to avoid cross-year retroactive repayments;

Strengthen full-chain invoice and voucher management, embed compliance review into all business links, verify supplier qualifications and transaction authenticity to ensure “four-flow consistency”, and prevent false invoicing and input deduction risks;

Proactively establish liquidation ledgers for stock projects of land appreciation tax, environmental protection tax, etc., sort out historical legacy risks, conduct self-inspection and rectification in advance to avoid cumulative risks leading to large repayments and late fees.

 

4.2 Standardize Tax-Related Disposal Processes to Reduce Repayment and Late Fee Losses

Upon receiving tax risk warnings, self-inspection prompts, or inspection notices:

Immediately form a special task force, sort out transaction materials, accounting vouchers, and policy bases, conduct rigorous compliance self-inspection, objectively define risk nature and liability boundaries, and avoid blind tax repayment;

Maintain professional communication with tax authorities, submit written explanations and supporting materials for disputes (policy application, tax base determination, retroactive period), and strive for flexible solutions (reasonable policy caliber, installment payment) to ease cash flow pressure;

Exercise administrative reconsideration and litigation rights in accordance with the law to safeguard legitimate interests during the dispute resolution window;

Pay confirmed taxes in full and on time to control late fee accumulation; strictly comply with capital market information disclosure rules, truthfully disclose major tax matters, and conduct investor communication and public opinion management to avoid disclosure violations and secondary market shocks.

 

 4.3 Closed-Loop Review & Rectification to Build a Normalized Tax Compliance System

After resolving tax-related matters:

Conduct in-depth root-cause analysis of tax repayment reasons, non-compliant links, and management loopholes; classify issues (policy misunderstanding, inadequate internal controls, operational errors) and implement targeted closed-loop rectification;

Take individual cases as a warning to comprehensively rectify historical defects (non-compliant preferences, non-standard invoice management, under-declared specific taxes) and eliminate stock risks;

Establish full-cycle tax files for major projects, long-term assets, and tax preferences, and fully retain contracts, invoices, declaration records, and preference filing documents;

- Strengthen the tax team’s professional capacity, keep abreast of new laws (e.g., *VAT Law*) and enforcement changes, conduct regular policy training and practical drills, optimize internal tax control systems and business processes, and build a long-term tax compliance system adapted to strict supervision—protecting the company’s capital market reputation and long-term value through tax-compliant stable operations.