In a landmark development for internet platforms, the Chinese government has recently introduced a new regime mandating internet platforms to regularly report tax-related information to Chinese tax authorities. This new regime, formulated by the Provisions on the Reporting of Tax-related Information by Internet Platform Enterprises promulgated by the State Council (State Council Decree No. 810, "Regulation") and the accompanying State Taxation Administration (STA) Announcement on the Matters Relevant with Reporting of Tax-related Information by Internet Platform Enterprises (STA Bulletin [2025] No. 15, "Bulletin 15"), will significantly impact online platforms that are engaged in online transactions, covering both China domestic and overseas platforms (collectively as "Platforms").
The expansive scope means that even Platforms that previously operated with little oversight from Chinese tax authorities must now adhere to stringent reporting requirements. The new regime aims to close loopholes and bring more entities under the purview of the Chinese tax system, ensuring a level playing field for all market participants. As a result, Platforms need to invest in robust compliance systems and processes to fulfill reporting obligations and prevent potential penalties.
This client alert serves as an introduction of the key provisions and major implications of this new development on internet Platforms. Specifically, this article is divided into three main sections. In Section 1, we outline the key provisions of the Regulation and Bulletin 15 that warrant attention. In Section 2, we highlight the major implications on domestic and overseas Platforms, including the legal considerations related to data privacy and cross-border data transfer. Finally, in Section 3, we provide our advice on next-step actions for in-scope Platforms.
Jason Wen, Senior Tax Consulting Director, has contributed to this legal update.