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China Tax & Financial Compliance Review: We Check What Your Filings Don’t Show

Filing on time is the minimum. We go further — reviewing your invoices, expense records, and reporting patterns to identify compliance gaps before the tax bureau does. Proactive review is significantly less expensive than responding to an audit.

China’s tax authorities now cross-reference invoice data, bank transactions, and payroll records automatically. A pattern of unverified invoices, non-deductible expenses, or zero reporting is visible to the tax bureau before it is visible to you. We find these issues first.

Invoice Risk

Invoice Compliance Review

Every invoice your company issues or receives is recorded in China’s Golden Tax System in real time. We review your invoicing records to confirm that what you have booked reflects genuine transactions — and that the invoices themselves meet the standards required for deductibility and VAT recovery.

What We Do

  • Verify the authenticity of supplier invoices against the Golden Tax System
  • Check that sales invoices match the corresponding contracts and payment receipts
  • Identify high-risk invoices: abnormal amounts, unverifiable suppliers, or descriptions inconsistent with the underlying business
  • Assess whether invoices are supported by real underlying transactions
  • Identify invoices that cannot be used as deductible or VAT-creditable inputs
  • Flag patterns that may attract tax bureau attention under Golden Tax Phase IV monitoring

What You Provide

  • Invoice records for the review period (input and output)
  • Corresponding contracts and payment records

What You Receive

Invoice compliance review report. High-risk invoice list with specific recommendations for each item. Priority-ranked remediation plan — addressing the most exposed items first.

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Expense Risk

Expense & Deduction Compliance Review

Not all business expenses are tax-deductible in China — and the rules on what qualifies, how it must be documented, and what limits apply are detailed. We review your expense records to identify items that are likely to be disallowed in a tax audit and recommend how to correct them.

What We Do

  • Review expense claims for proper documentation — valid fapiao, business purpose, and authorisation
  • Check entertainment expenses against the 60% deduction cap (not to exceed 0.5% of annual revenue)
  • Identify non-deductible items: fines and penalties, personal expenses, non-business-related purchases
  • Review employee allowances and benefits for correct IIT and social insurance treatment
  • Check cross-border service payments — management fees, royalties, technical service fees — for correct withholding tax application
  • Identify expense patterns that may be questioned in a tax bureau review

What You Provide

  • Expense records and supporting vouchers for the review period
  • Cross-border payment records (if applicable)
  • Employee benefit and allowance details

What You Receive

Expense compliance review report. Non-deductible and at-risk expense list with specific remediation recommendations. Adjustments to apply in the annual CIT settlement to reduce audit exposure.

For ongoing monthly filing management, including tax declaration submission and bookkeeping, see our Tax Filing & Compliance service → and Accounting & Bookkeeping service →

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Reporting Risk

Zero Tax Reporting Risk

Zero tax reporting — filing returns showing no revenue and no tax liability month after month — is sometimes used as a cost-cutting measure by companies that are not yet operational or have paused activity. It is one of the most commonly misunderstood compliance risks for foreign-invested companies in China.

The core problem is not the filing itself — nil returns are legitimate for genuinely inactive periods. The risk arises when zero filings continue while the company has actual bank activity, employee payments, or business transactions that are visible to the tax bureau through cross-system data matching.

What We Do

  • Assess whether your current zero-reporting status is consistent with your actual operational activity
  • Cross-reference your tax filings against bank statement activity to identify visible discrepancies
  • Identify the point at which zero reporting becomes a material audit trigger
  • Recommend a remediation path — catching up on unreported activity in a structured way
  • Advise on the correct approach for genuinely pre-revenue or dormant entities

What You Provide

  • Recent tax declaration records
  • Bank statements for the same period (for cross-referencing)

What You Receive

Zero tax reporting risk assessment. Clear view of whether your current filing pattern is defensible. Recommended remediation steps and timeline where a gap exists.

Why we strongly discourage long-term zero tax reporting — and what we have seen happen to clients who maintained it too long. Read our in-depth guide based on real cases.

Read the Guide →

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Quick Answers

Frequently Asked Questions

Is an invoice compliance review the same as bookkeeping?

No. Bookkeeping is the ongoing process of recording transactions and preparing financial statements. An invoice compliance review is a point-in-time assessment of whether the invoices already in your books meet the standards required for deductibility, VAT recovery, and audit defence. The two services complement each other — bookkeeping creates the records, compliance review checks their quality. For ongoing bookkeeping, see our Accounting & Bookkeeping service →

Are entertainment expenses deductible in China?

Partially. Business entertainment expenses (业务招待费) are deductible at 60% of the amount incurred, subject to a cap of 0.5% of annual revenue — whichever is lower. Expenses above this limit are non-deductible and must be added back in the annual CIT settlement. Documentation requirements are strict: the invoice must clearly describe the nature of the entertainment, and the business purpose should be documented. Personal entertainment or expenses without a valid fapiao are entirely non-deductible.

We have been filing zero returns for two years. How serious is the risk?

The answer depends on whether any actual financial activity occurred during those two years. If the company genuinely had no transactions, no bank activity, and no employees, zero filing is defensible. If there was any activity — payments, transfers, salary, or service fees — that was not reported, the gap between your filings and the data visible to the tax bureau creates material audit risk. The longer the gap continues, the larger the potential back-tax, interest, and penalty exposure. We assess your specific situation and recommend a structured remediation approach. For further context, read our guide: Why We Strongly Discourage Long-Term Zero Tax Reporting →

What typically triggers a tax bureau audit?

Common audit triggers include: sustained zero or near-zero tax filings inconsistent with industry norms; large discrepancies between VAT invoicing and bank receipts; unusual expense patterns, particularly high entertainment or management fee ratios; cross-border payments without proper withholding tax treatment; and data mismatches identified through Golden Tax Phase IV’s automated cross-referencing. A proactive compliance review identifies which of these patterns exist in your records before they attract attention.

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Want us to review your China tax and financial compliance?

We identify invoice risks, expense gaps, and reporting patterns that create audit exposure — before the tax bureau does.

Book a Consultation