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Potential Tax Audits in Shanghai


The Shanghai Municipal Tax Bureau has recently made public, following the requirements in the circulars Shuizongfa [2015] No. 104, Guofa [2019] No. 5 and other relevant regulations, a work arrangement of tax audits on randomly selected targets in 2020.

1. Target pool and source for random tax audits

a) Key audit targets: selected, based on such factors as tax scale, industry, geographic location, type of registration, group companies and others on a comprehensive basis, from the key tax source enterprises in Shanghai

b) Non-key audit targets: randomly selected from the pool of taxpayers other than the key audit targets, including non-enterprise taxpayers

c) Abnormal audit targets: selected from the pool of enterprises having made abnormal tax declarations, having high tax risks or low tax credit rating, reported many times due to tax violations, having many violation records in tax collection and administration, listed by the relevant authorities as joint punishment targets due to violation of the laws or having other abnormal situations

2. Methods for selecting the targets for audits

Targets will be randomly selected through a screening process with or without specific conditions.

3. Periods for random tax audits

For the randomly selected tax audit targets, their tax compliance performance and other tax law compliance status during the period from 2017 to 2019 will be audited. If any major tax violation action is found, the audit period can be traced back to the prior years or extended to 2020.

4. Forms of tax audits

The target taxpayer will either (1) directly be audited or (2) be required to conduct self-inspections followed with the audit.


Portrait of Gilbert Shen
Gilbert Shen, CPA