Editor's Note: In June 2025, the Provisions on the Submission of Tax-related Information by Internet Platform Enterprises (State Council Decree No. 810) officially came into effect, establishing the content of obligations and supporting liabilities for platform tax-related information submission. The Tax Collection and Administration Law of the People's Republic of China (Revised Draft for Solicitation of Opinions) proposes to further strengthen submission liabilities. Focusing on the core obligation of tax-related information submission, this article reviews the evolution of the rules, analyzes the specific methods by which tax authorities use submitted data for supervision, and proposes compliance recommendations for platform enterprises and business operators respectively.

I. The Gradual Escalation of Tax-related Information Submission Obligations

Platform tax-related information submission was not newly created in 2025, but its legal hierarchy, intensity of liability, and enforcement have undergone a gradual escalation from soft constraints to hard constraints. The obligation for platforms to submit tax-related information first appeared in Article 28, Paragraph 2 of the E-Commerce Law of the People's Republic of China, which took effect in 2019: “E-commerce platform operators shall, in accordance with tax collection and administration laws and administrative regulations, report to tax authorities the identity information of operators on the platform and tax-related information.” This provision was only stated in principle, without clarifying operational details such as the specific scope, timing, and calibre of submission, nor was it accompanied by clear penalty standards. In practice, tax data submission mostly took the form of special tax collection notices and case-specific investigation assistance requirements, with no unified operational norms.

On this basis, the Provisions on the Submission of Tax-related Information by Internet Platform Enterprises (State Council Order No. 810, hereinafter referred to as “Decree No. 810”), which officially came into effect in June 2025, refined the platform tax-related information submission obligation at the institutional level: it clarifies the status of platform enterprises as the main subjects of submission, extending the scope of application from traditional e-commerce to all e-commerce platform operators and other legal persons or unincorporated organizations that provide profitable services such as online business premises, transaction matching, and information publishing for online transaction activities; it establishes a quarterly routine submission mechanism, uniformly requiring platforms to report core data such as identity information and income information of operators and practitioners on the platform; and it provides tiered penalties, specifying that failure to submit on schedule shall first be ordered to make corrections within a time limit, with a fine of RMB 20,000 to RMB 100,000 if corrections are not made within the time limit, and a fine of RMB 100,000 to RMB 500,000 in serious cases, along with possible order to suspend business for rectification. Thus, platform tax-related information submission has formally risen from fragmented tax collection cooperation matters to a legal obligation that platform enterprises must fulfill, providing a solid institutional foundation for subsequent tax supervision.

In March 2025, the Ministry of Finance and the State Taxation Administration published the Tax Collection and Administration Law of the People's Republic of China (Revised Draft for Solicitation of Opinions) and opened it for public comment. Article 72 stipulates: “Whoever fails to submit identity information and tax-related information in accordance with Paragraph 1 and Paragraph 2 of Article 29 of this Law shall be ordered by the tax authority to make corrections within a time limit; if corrections are still not made after the time limit, a fine of not less than RMB 20,000 but not more than RMB 100,000 shall be imposed by the tax authority; in serious cases, a fine of not less than RMB 100,000 but not more than RMB 500,000 shall be imposed; in especially serious cases, a fine of not less than RMB 500,000 but not more than RMB 2,000,000 shall be imposed, and the relevant competent department may order suspension of business for rectification. Whoever fails to handle tax filing for platform operators and practitioners in accordance with the provisions of this Law shall be ordered by the tax authority to make corrections within a time limit; if corrections are still not made after the time limit, e-commerce platform operators and other online transaction platform operators shall be fined not less than 50% but not more than three times the amount of tax unpaid or underpaid by platform operators and practitioners.” This means platforms must cooperate with submission obligations, otherwise they will bear corresponding penalties.

In early 2026, Shanghai Xunmeng Information Technology Co., Ltd. failed to complete the Q3 2025 tax-related information submission for platform operators on schedule, and still failed to do so after being ordered by the tax authority to make corrections within a time limit. It was fined RMB 100,000 by the Changning District Tax Bureau of Shanghai, becoming the first administrative penalty nationwide against a platform for its submission obligation since the implementation of Decree No. 810. According to disclosed information, tax authorities have further clarified that the trigger for a platform's tax-related information submission obligation is based on transaction records generated on the platform: as long as there are transaction records, information must be submitted, regardless of whether the platform handles transaction funds or charges service fees. Meanwhile, tax authorities have also emphasized that obligation fulfillment has strict time limits, and retroactive submission does not fully exempt from overdue liability—once the ordered correction period is exceeded, penalties will be triggered.

II. The Current State of Penetrating Supervision Driven by Submission Obligations

Driven by submission obligations, tax authorities have access to more transparent information, and platform enterprises and on-platform business operators face different tax compliance risks respectively.

(1) Clear Statutory Requirements, Significantly Increased Platform Liabilities

From the perspective of legal hierarchy, after the implementation of Decree No. 810, the submission liability of platform enterprises has become an explicit statutory liability. Compliance covers all formats of matching-type platforms, including both registered operators on the platform and practitioners providing services under personal names. The content is standardized, requiring quarterly submission of core data such as identity information and income information, and the platform is responsible for the authenticity, accuracy, and completeness of the submitted information. In addition, penalties are set in tiers, establishing a progressive liability system from ordering corrections to fines and suspension of business for rectification. With continuously intensifying supervision and increasingly clear statutory requirements, platforms primarily face the following risks:

First, the risk of overdue submission. Decree No. 810 requires platforms to submit tax-related information quarterly. For failure to submit on schedule, the tax authority first orders corrections within a time limit; if corrections are still not made after the time limit, a fine of not less than RMB 20,000 but not more than RMB 100,000 shall be imposed; in serious cases, a fine of not less than RMB 100,000 but not more than RMB 500,000 may be imposed, along with an order to suspend business for rectification. Shanghai Xunmeng Information Technology Co., Ltd. was fined RMB 100,000 precisely because it failed to complete the Q3 2025 information submission on schedule and still did not complete it after being ordered to make corrections within a time limit. Furthermore, according to the Tax Collection and Administration Law (Revised Draft), the maximum fine for submission violations is proposed to be raised to RMB 2 million, further increasing the cost of overdue submission.

Second, the risk of inaccurate submission. According to Article 6 of Decree No. 810, platforms shall verify the tax-related information of platform operators and practitioners, and are responsible for its authenticity, accuracy, and completeness. According to Item (2) of Article 10 of Decree No. 810, concealment, false reporting, or omission of tax-related information, or circumstances where tax-related information is untrue, inaccurate, or incomplete due to reasons attributable to the platform enterprise, shall be ordered by the tax authority to make corrections within a time limit, with fines imposed if corrections are not made within the time limit. If there is a significant discrepancy between the data submitted by the platform and actual transaction conditions—for example, omission of platform operators or inaccurate income data—it may be deemed a failure to submit information as required, exposing the platform to fines. Platform transaction scenarios are complex, with frequent occurrences of order brushing, refunds, and non-monetary transactions. Without unified internal data standards and verification mechanisms, discrepancies between submitted data and actual conditions are likely to arise.

Third, the risk of assisting tax evasion. The data submitted by platforms is an important basis for tax authorities to conduct tax inspections. If a platform intentionally conceals transactions for operators, tampers with data, or assists in splitting income, resulting in operators failing to pay or underpaying taxes, its conduct may very likely be deemed as “illegally providing other conveniences to taxpayers” as stipulated in Article 93 of the Detailed Rules for the Implementation of the Tax Collection and Administration Law. According to this provision, whoever illegally provides bank accounts, invoices, certificates, or other conveniences to taxpayers or withholding agents, causing tax non-payment or underpayment, shall have illegal gains confiscated by the tax authority and may be fined not more than one time the amount of tax unpaid, underpaid, or defrauded. Furthermore, according to Article 19 of the Interpretation of the Supreme People's Court and the Supreme People's Procuratorate on Several Issues Concerning the Application of Law in Handling Criminal Cases of Endangering Tax Collection and Administration: “Whoever, knowing that another person is committing a crime endangering tax collection and administration, still provides account numbers, credit certificates, or other assistance thereto, shall be treated as an accomplice in the corresponding crime.” If a platform knowingly provides assistance in furtherance of a crime, it may be suspected of criminal offense.

(2) On-platform Operators: Heightened Risks of Concealing Income and Tax-related Violations

For merchants, individual industrial and commercial households, and other business entities on the platform, the core risk is that the unlawful concealment of income will be investigated and penalized. Under the traditional invoice-based tax administration model, tax authorities previously found it difficult to comprehensively grasp the scale of transactions on platforms. Some operators harbored the fluke mentality that “as long as funds do not go through corporate accounts and no invoices are issued, it cannot be detected,” and resorted to zero filing or filing significantly below actual scale. However, as full-volume transaction data from platforms is regularly submitted to tax authorities, significant discrepancies between the two will directly trigger risk warnings. In the Changde Senmu Trading case announced by tax authorities on August 25, 2026, an enterprise earned RMB 343 million in revenue on the platform over six months but filed zero returns. Tax authorities detected the anomaly precisely by comparing the business data declared by the platform with the tax filing data, and ultimately the enterprise had to make up tax payments plus fines totaling approximately RMB 13.77 million.

Some operators, upon learning that platforms submit information, have attempted to muddle through by making sudden retroactive filings, causing short-term sharp fluctuations in declared income without reasonable business justification. These have also been identified by tax big-data risk models. In a Tianjin restaurant case disclosed by the China Taxation News, the operator's Q3 declared income surged more than 40-fold quarter-on-quarter without reasonable grounds such as store expansion or large-scale promotions. The abnormal fluctuation directly became the trigger for case filing and investigation, ultimately verifying RMB 48.02 million in undeclared income.

In addition, risks associated with violations such as order brushing to inflate sales and abuse of tax incentives have also been amplified simultaneously. Fake orders generated by brushing are fully submitted by the platform, and discrepancies with actually declared income easily trigger audits; moreover, operators asserting that brushed orders should not be subject to tax bear an extremely heavy burden of proof. Arrangements such as registering multiple shell entities to split income or abusing approved levy collection and other tax incentives can be undone once tax authorities integrate data across multiple platforms to reconstruct true income. Once deemed to lack a reasonable commercial purpose, operators will face tax adjustments and retroactive supplementary payments.

III. Compliance Management: Risk Prevention Pathways Aligned with Regulatory Logic

In response to the aforementioned risks, platform enterprises and business operators must closely align with the regulatory logic of data submission, implement targeted measures corresponding to risk points, and build a compliance system at the institutional, procedural, data, and evidentiary levels to proactively adapt to regulatory requirements.

(1) Platform Enterprises: Focus on Full-process Compliance of Submission

First, optimize the submission workflow to prevent and control overdue submission risks. Establish a closed-loop working mechanism, clarify the responsibility boundaries among business, finance, legal, and other departments, and reserve sufficient time for verification and rectification after the end of each quarter to avoid delays in submission caused by data quality issues. Upon receiving a notice of correction ordered by a tax authority, strictly complete rectification within the statutory time limit to prevent penalties due to overdue.

Second, unify submission standards to prevent and control inaccurate submission risks. In accordance with the requirements of Decree No. 810 and supporting announcements, formulate internal submission data specifications, clearly defining the transaction scope and income calculation rules included in submission; establish unified handling standards for special scenarios such as order brushing, cancelled orders, refunds, and non-monetary consideration, and retain corresponding supporting materials simultaneously. Establish a regular reconciliation mechanism, cross-verify platform backend order data with actual settlement funds, retain reasonable explanations and supporting materials for data discrepancies, and proactively manage data deviations.

Third, improve the evidence retention system to prevent and control risk escalation. Properly preserve materials such as operator identity verification records, transaction details, settlement vouchers, platform rules, and cooperation agreements, with retention periods meeting statutory tax collection requirements, forming a complete chain of evidence. Meanwhile, draw clear compliance boundaries: do not provide conveniences for operators to conceal or split income, to avoid escalating from a submission obligation subject to a tax violation subject.

(2) On-platform Business Operators: Rebuilding Financial and Tax Compliance Logic

First, comprehensively standardize income accounting and strictly prohibit income concealment. Strictly distinguish between business accounts and personal accounts, collect all business income through corporate accounts, eliminate practices of private account collection and off-book settlement, include all taxable income in standardized accounting, and file tax returns truthfully in accordance with the law, eliminating discrepancy risks from data comparison at the source.

Second, maintain self-consistent filing logic to prevent and control abnormal fluctuation warning risks. Ensure that tax filing data matches platform order data, corporate account bank flows, and business system data in scale and trend, avoiding significant fluctuations without reasonable justification. For reasonable differences arising from refunds, order brushing, platform deductions, and similar items, separately retain corresponding vouchers so that reasonable explanations can be provided during tax verification.

Third, proactively conduct self-inspection and rectification to reduce the risk of penalty escalation. Conduct self-inspection of existing business since the implementation of the submission system, focusing on investigating off-book settlement, undeclared income, and other issues, formulate rectification plans, and proactively resolve historical burdens. When facing tax inspections, proactively provide materials and explain circumstances, avoiding situations of going dark or refusing to cooperate; proactively cooperating with inspections and voluntarily making up tax payments are important factors in seeking lighter or mitigated penalties.

IV. Conclusion

The tax-related information submission system established by Decree No. 810 is a foundational project of the “data-driven tax administration” supervision system for the platform economy. With the first penalty imposed and enforcement continuously strengthening, the submission obligation has transformed from paper rules into tangible compliance pressure, and has also underpinned a comprehensive data supervision environment. In the short term, the implementation of new regulations will raise compliance costs across the industry, some historically off-book issues may surface in concentrated fashion, and small and medium-sized business operators will face compliance growing pains; but in the long run, a transparent and fair tax environment will eliminate non-compliant entities, promote healthy industry development, and ultimately realize the standardized development of the industry as a whole. It is recommended that platform enterprises and operators abandon the traditional mindset that “information asymmetry enables tax avoidance,” proactively integrate compliance management into the entire business process, and jointly adapt to the tax administration requirements under the data supervision environment through standardized fund settlement, clarified obligation boundaries, improved evidentiary systems, and the establishment of risk control mechanisms. At the same time, it is also recommended that regulatory authorities consider the operational characteristics of the platform economy, provide reasonable transition periods and guidance during law enforcement, and through the joint efforts of both tax authorities and taxpayers, achieve a balance between protecting tax interests and promoting the development of new business formats.