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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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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Latest from Hendersen
2026-08-27 · Featured
State Taxation Administration Issues Document Clarifying Collection and Administration Issues Concerning Income Tax Treatment of Enterprise Reorganization
Recently, the State Taxation Administration issued the “Announcement on Certain Collection and Administration Issues Concerning Income Tax Treatment of Enterprise Reorganization” (2026 No. 13, hereinafter referred to as the “Announcement”). This policy is primarily applicable to enterprises with relatively dispersed equity structures and complex shareholder compositions (including corporate shareholders, individual shareholders, partnerships, etc.), and is also specifically formulated for merger and division transactions of listed companies.
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2026-07-27
【BREAKING】New Offshore Trust Rules
On July 24, the Ministry of Finance and the State Taxation Administration jointly issued Announcement No. 21 of 2026, signaling that the individual income tax loophole for offshore trusts has been formally closed. The most critical signal is this: obtaining a foreign identity no longer equates to severing one's Chinese tax obligations. No matter how many layers of “shell” structures are in place, as long as the economic substance ultimately rests with a Chinese individual, the tax treatment must follow China's tax laws to completion.
2026-07-23
When "State Ownership" Is Deemed "Related-Party" Status — A Full Review of MMG's Thin Capitalization Litigation Case in Peru
The Peruvian tax authority advanced an unprecedented legal logic: because MLB's ultimate controlling shareholder, China Minmetals Corporation, is a central state-owned enterprise, and the lending institutions — China Development Bank and The Export-Import Bank of China — are also central state-owned enterprises, both parties are “under the control of the Chinese government,” and therefore they constitute a related-party relationship. If this logic were to prevail, all cross-border transactions among Chinese state-owned enterprises would be redefined.
2026-07-02
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.
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.