Taxand Global Alliance · China Member Firm
Your cross-border tax partner in China.
Independent advice on China tax, M&A, transfer pricing and outbound structuring — from a senior team that has done it for 20 years.
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One Chinese partner firm in the world's largest independent tax alliance.
Hendersen is the sole China member of Taxand — 700+ partners, 2,000+ advisers, 54+ countries. Cross-border engagements are coordinated directly with the relevant Taxand firm, with no intermediaries.
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Corporate Tax
China tax compliance and advisory for inbound and outbound structures.
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Tax due diligence, deal structuring, valuation support and post-merger integration.
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Cross-border investment planning and tax-efficient holding structures.
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Accounting, payroll and tax filings managed end-to-end.
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Individual income tax, equity incentives, and expatriate tax planning.
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Tariff classification, transfer pricing documentation, customs valuation.
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TP documentation, benchmarking studies and risk reviews.
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Cross-border wealth structuring, estate and succession planning.
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Latest from Hendersen
2026-07-02 · Featured
Lessons from Jushi Group's Egypt share-transfer case for resolving international tax disputes
When a Chinese listed company transfers the shares of an overseas subsidiary, where should tax be paid — China or the host state? A seemingly simple question once put global fibreglass leader Jushi Group within reach of RMB 140 million in irrecoverable tax. This cross-continental dispute between Asia and Africa ultimately ended with the Chinese position fully accepted by the Egyptian tax authorities. The case offers a textbook example of (i) the priority of bilateral tax treaties over domestic tax law, (ii) the limits of cross-treaty analogy, and (iii) a clean three-step framework for analysing share-transfer taxing rights under the China–Egypt treaty — with the Chinese tax authorities, through provincial and central tax bureaus, securing the favourable outcome.
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2026-06-23
Hong Kong's tax transparency moves into criminal enforcement: the first CRS conviction
In March 2026, a Hong Kong court handed down the jurisdiction's first criminal CRS conviction: a private-banking client who made a false statement about the beneficial owner of a Seychelles-incorporated offshore company was sentenced to 6 months' immediate imprisonment and a HKD 500,000 fine. The case marks the moment Hong Kong's CRS supervision moved from administrative enforcement to criminal prosecution. Hong Kong is also accelerating domestic legislation for CRS 2.0 and the Crypto-Asset Reporting Framework (CARF), with administrative-framework amendments expected to take effect on 1 January 2027 and CRS 2.0 full exchange by 2029.
2026-03-17
2025 update to the OECD Model Tax Convention Commentary: a new framework for home-office PE risk
On 19 November 2025, the OECD released a key update to the Commentary on Article 5 (Permanent Establishment) of the Model Tax Convention, addressing the cross-border home-office PE risk that has grown with the normalisation of remote work. Rather than abolishing the existing 'right of use' test, the update overlays two practical thresholds: a 50% time-share safe harbour and a 'commercial reasonableness' substantive test, both built around the share of time an employee spends working from a non-employer-owned location in any rolling 12-month period. The result is a more predictable framework for cross-border workforce tax planning — and the central reference point for 2026 PE compliance.
2025-09-19
A new era for platform-economy taxation in China: unpacking Announcement 16
On 26 June 2025, the SAT released two companion announcements reshaping platform-economy tax administration: Announcement 15 (information reporting by platform enterprises, effective 26 June 2025) and Announcement 16 (withholding/agency filing for platform workers, effective 1 October 2025). Together they establish a complete information-reporting and withholding framework for e-commerce sellers and livestream hosts. Announcement 16's key shifts: (i) withholding on labour-service remuneration switches from the 20–40% progressive schedule to the cumulative 3–45% schedule with a RMB 5,000 monthly deduction; (ii) small-scale taxpayer VAT exemption (monthly sales under RMB 100k) and 1% concessionary rate apply to platform workers' service income; and (iii) platforms can claim CIT deduction for amounts paid to workers using the new withholding/agency-filing receipts. The Douyin platform has since issued new rules implementing these changes.
2025-08-21
How to view the latest tax policies for Hainan Fuxing City Internet Information Industry Park
At the 23 July 2025 State Council Information Office briefing, Vice-Minister of Finance Liao Min and other senior officials outlined the goods-tax framework that will apply once the Hainan Free Trade Port ('Hainan FTP') moves to island-wide customs closure ('full closure'). The key shifts: (1) the zero-tariff positive list becomes a negative list covering ~6,600 HS codes (≈74% of all codes, up ~53 pp); (2) the eligible-entity pool expands beyond independently registered legal-person enterprises to cover most on-island enterprises, public institutions and private non-enterprise units; and (3) zero-tariff goods (and products processed from them) can flow freely between eligible entities on the island. For Hainan Fuxing City — one of the 13 key FTP parks — the headline numbers remain a 15% CIT rate, a 15% top IIT rate, and 18 taxes simplified to 7.
2025-06-19
Tightening CRS information exchange — how should China tax residents declare offshore income and claim foreign tax credit?
China's tax authorities are increasingly relying on Golden Tax Phase IV and cross-departmental data analytics to identify undeclared offshore income. Two recent cases — a Shanghai resident who paid RMB 184,800 and a Shandong resident who paid RMB 1.26 million in back-taxes and penalties — illustrate the trend. With 100+ jurisdictions (including Hong Kong, Singapore, Switzerland and the traditional offshore centres) now signed up to CRS, and the US operating under a parallel FATCA regime, Chinese tax residents holding offshore accounts should expect far less cover. We outline the categories of offshore income most likely to be flagged, the foreign-tax-credit mechanics under SAT Announcement [2019] No. 35 and the DTA framework, and the practical steps to take before the annual settlement window (1 March – 30 June).
2025-02-05
Spanish Participation Exemption Confirmed as “Full Exemption” for CFC Regime
A note from Garrigues, Taxand Spain — The Spanish Directorate General of Taxes (DGT) has clarified that dividends and capital gains benefiting from Spain's participation exemption are treated as fully exempt under the CFC regime. Foreign holding companies receiving such income are not required to declare it in Spain, subject to standard CFC conditions including the 75%-of-Spanish-tax test."