China’s New Tax Reporting Rules Are a Game Changer for Overseas Internet Platforms

China’s new reporting rules will require Chinese domestic and international internet platform enterprises to submit tax-related information to Chinese tax authorities.

The Chinese government has introduced a set of new regulations requiring internet platforms to report tax-related information to Chinese tax authorities. These rules affect both Chinese domestic and international “internet platform enterprises,” extending jurisdiction to overseas platforms regardless of their physical presence in China, by mandating the reporting of identity and income information for Chinese merchants and individual practitioners (从业人员), referring to natural persons who provide profit-making services in their own name through internet platforms—a term that can broadly capture livestreamers, influencers, freelancers, and other individuals monetizing services via digital channels.

The State Taxation Administration of the People’s Republic of China (STA) reported that, as of October 15, over 4,100 domestic and overseas internet platforms, including major players like Pinduoduo, Ele.me, Didi, and international cross-border marketplaces, have submitted their first round of tax-related information.

This LawFlash explores the specific reporting requirements under the new regulations, examines their impact on Overseas Platforms, and provides best practice recommendations for multinational companies to keep compliance.

BACKGROUND

On June 20, 2025, the State Council of the PRC issued the Provisions on the Reporting of Tax-related Information by Internet Platform Enterprises (State Council Decree No. 810, Provisions), which took effect immediately. The Provisions outline the basic requirements for internet platform enterprises to submit tax-related information and authorize the STA to formulate implementation measures.

Shortly after, on June 26, 2025, the STA released two circulars: (1) the Announcement on Matters Relevant to the Reporting of Tax-related Information by Internet Platform Enterprises (STA Circular [2025] No. 15, Circular 15), effective June 26, 2025, which details specific reporting requirements and guidelines for various types of “internet platform enterprises,” particularly “overseas internet platform enterprises” (referred to as Overseas Platforms), to report the tax-related information to Chinese tax authorities; and (2) the Announcement on Several Matters Concerning Withholding Declaration and Agency Declaration by Internet Platform Enterprises for Individual Practitioners on the Platform, effective October 1, 2025, which addresses platforms’ obligations to withhold taxes for individual practitioners, accompanied by the STA’s official interpretation of the two circulars.

Furthermore, the STA, in collaboration with the Ministry of Industry and Information Technology (MIIT) and the Cyberspace Administration of China (CAC), jointly issued the Announcement on Administrative Penalty Matters Concerning the Regulation of Tax-Related Information Reporting by Internet Platform Enterprises (Joint Announcement), effective September 28, 2025, focusing on the enforcement of the Provisions.

These regulations collectively establish the framework for tax-related information reporting by internet platform enterprises to Chinese tax authorities.

WHAT ARE ‘OVERSEAS INTERNET PLATFORM ENTERPRISES’?

Following the Provisions, Circular 15 further clarifies the concept of “overseas internet platform enterprises.” They are defined as “legal entities or unincorporated organizations established under offshore jurisdictions that operate internet platforms through domain names outside of China, providing profit-making services such as online business premises, transaction facilitation and information publishing to Chinese domestic merchants.” [1]

Circular 15 also outlines eight categories of “internet platforms” covered by the Provisions:

• Online retail platforms
• Livestreaming platforms
• Online freight platforms
• Flexible employment platforms
• Platforms providing services such as education, healthcare, travel, consulting, training, brokerage, design, performance, advertising, translation, agency services, technical services, audiovisual content, gaming and entertainment, online, literature, artificial intelligence (AI)–generated content, and online lending
• Aggregation service platforms
• Mini-programs and quick apps providing commercial services, as well as platforms providing infrastructure services for such mini-programs and quick apps
• Other platforms facilitating commercial transactions via online networks

HOW CAN OVERSEAS PLATFORMS CONDUCT THE REPORTING?

According to Article 1 of Circular 15, Overseas Platforms must report tax-related information to Chinese tax authorities in a designated manner, based on their specific circumstances:

• Platforms with Licensed Chinese Entities: If an Overseas Platform has established operating entities in China with a value-added telecommunications business operation permit, such Chinese permit-holding entity shall submit the tax-related information.
• Platforms with Chinese Entities but No License: If an Overseas Platform has operating entities in China but without the necessary permit, the Chinese entity providing services like merchant settlement, store operation, and marketing promotion must submit the tax-related information.
• Offshore Platforms with No Presence in China: If no local presence is established in China, the Overseas Platform must designate a domestic agent in China to submit the information.

WHAT INFORMATION IS REQUIRED TO BE REPORTED?

Overseas Platforms must report comprehensive information using forms developed by the STA, [2] including the following:

• Basic Platform Information [3]
  • Basic information of the reporting entity, among others, name, unified social credit code and license/record number
  • Basic information of the platform, among others, name, domain name, type of services and date of operation commencement
• Basic information of any other operating entities that participate in the platform's operations, among others, name, taxpayer identification number, and performed functions
• Identity Information of Merchants and Individual Practitioners [4]
  • Identity details for Chinese merchants and individual service providers
  • Offshore platforms are required to report identity details only for Chinese merchants and individual practitioners
• Income Information of Merchants and Individual Practitioners [5]
  • Income details from provision of services and sales of intangible assets to Chinese purchasers in the previous quarter
  • Reporting of income details is exempted if an individual Chinese purchaser’s quarterly cumulative transaction amount is no more than 5,000 renminbi

WHEN SHOULD TAX-RELATED INFORMATION BE REPORTED?

Initial Reporting

Circular 15 [6] mandates that new internet platforms must report within 30 days of starting business.

For existing internet platforms, they must report their basic platform information by July 30, 2025, and complete the first submission of verified identity and revenue information for merchants and individual practitioners by October 31, 2025.

Ongoing Reporting

All internet platform enterprises must submit quarterly reports of identity and revenue details for merchants and individual practitioners from the previous quarter, due within one month after each quarter ends.

Any changes to basic information must be reported within 30 days of occurrence, and corrections to reporting errors must be submitted within 30 days of discovery.

WHAT ARE THE CONSEQUENCES OF NONCOMPLIANCE?

The Provisions impose substantial penalties for noncompliance. [7] Specifically, if an internet platform enterprise engages in any of the following actions, the tax authority will order corrections within a specified time:

• Failing to report and provide tax-related information by the prescribed deadline
• Concealing, misreporting, or omitting tax-related information, or causing it to be untrue, inaccurate, or incomplete
• Refusing to report or provide tax-related information

Failure to comply will result in a fine ranging from 20,000 renminbi to 100,000 renminbi. In serious cases, the business may be ordered to suspend operations for rectification, with increased fines ranging from 100,000 renminbi to 500,000 renminbi.

The Joint Announcement further clarifies “serious cases” by outlining six specific situations, emphasizing the regulators’ commitment to combating noncompliance and ensuring that the Provisions are effectively implemented. Additionally, companies ordered to suspend business may face further administrative liabilities related to their value-added telecommunications business operation permit and restrictions on issuing tax invoices (fapiao).

IMPLICATION ON OVERSEAS PLATFORMS AND RECOMMENDATIONS

The new regulations impose strict reporting obligations on Overseas Platforms that previously operated with minimal oversight from Chinese tax authorities.

These platforms must now verify and standardize tax-related information for all Chinese merchants and individual practitioners, and is responsible for its accuracy, authenticity, and completeness. This requires developing new internal processes, such as upgrading IT systems for data collection, processing and transfer, and streamlining internal workflow to handle ongoing quarterly and contingent reporting.

The regulations also require Overseas Platforms to report the personal data of individuals conducting transactions through the internet platforms. They must determine whether providing this data to Chinese tax authorities complies with data privacy and cross-border data transfer laws in the relevant jurisdictions.

Internet platforms with active Chinese merchants and individual practitioners should prepare for these new reporting requirements. We recommend the following actions.

Conduct a Comprehensive Impact Assessment

Evaluate the applicability of the new reporting regime to the company’s business model. Identify and map China-facing revenue streams, and pinpoint potential gaps in data management, systems, and legal compliance.

Companies operating hybrid models—such as first-party sellers sourcing extensively from Chinese suppliers or using integrated supplier portals for onboarding, logistics, or payment coordination—may fall under the regime, appearing “platform-like” to Chinese tax authorities due to the management of large volumes of supplier data domestically.

Multinational companies with China sourcing or data-handling functions should reassess their exposure, anticipate possible reporting demands, and prepare strategic responses to limit disclosure scope and preserve business confidentiality while maintaining compliance with the new regime.

If necessary, companies should consult with China tax professionals to ensure comprehensive compliance.

Establish Efficient Reporting Workflows

Develop a comprehensive workflow for collecting and validating the identity and income information of merchants and individual practitioners on the platform. Ensure the process aligns with legal requirements for preparing and submitting the reports to Chinese tax authorities.

The Provisions state that if tax-related information is untrue, inaccurate, or incomplete due to the fault of operators or employees within the platform, the internet platform enterprises will not be held responsible, provided they have fulfilled their obligation to verify the submitted tax-related information.

It is important for Overseas Platforms to demonstrate to the Chinese tax authorities that they have made reasonable efforts to verify the relevant data.

Furthermore, Overseas Platforms should be prepared to provide supporting information, such as contract orders, transaction details, capital accounts and logistics, within the prescribed timeline if investigated by Chinese tax authorities.

Develop Secure Internal Systems

Implement robust systems for securely collecting, processing and transmitting tax-related personal and financial information. Ensure that any information disclosure to regulators is aggregated or deidentified and complies with the data privacy law in relevant jurisdictions. Adhere to legal standards and best practices for data protection and regulatory reporting.

Monitor Upcoming Regulations

Diligently monitor upcoming regulations concerning cross-border data transmission requirements, technical interface standards, and broader implications for China tax compliance. Ensure alignment with evolving legal obligations and prepare for necessary adjustments to maintain compliance.