In 2025, China's real estate industry maintained an in-depth adjustment trend, with the market showing distinct structural differentiation characteristics amid contraction. Nationwide real estate development investment and new commercial housing sales volume both saw significant corrections compared to the peak in 2021, and the development climate index remained in a low range. Regional market differentiation intensified: core cities maintained certain market vitality relying on resource endowments, while some cities faced sustained de-stocking pressure. Against this backdrop, the central and local governments have formed a policy synergy. On one hand, targeted tax reduction measures have been implemented to alleviate enterprises' capital pressure, such as reducing the pre-collection rate of Land Value Increment Tax (LVIT), optimizing deed tax incentives, and clarifying tax exemption conditions for ordinary residential properties. On the other hand, focusing on standardized tax administration, the State Taxation Administration issued the "Announcement on Several Administrative and Collection Guidelines for Land Value Increment Tax," unifying key rules including the connection between pre-collection and liquidation, and standards for deductible items. However, the formal legislation on LVIT has not yet been finalized. The regulatory system centered on the Interim Regulations and Implementing Rules can no longer fully adapt to the complex industry practices, and the problem of significant differences in regional implementation standards has not been fundamentally resolved. Coupled with the strengthened cross-departmental data sharing and full-process risk monitoring under the digital transformation of tax administration, the risk of tax-related disputes for real estate enterprises continues to be prominent.

From the perspective of dispute areas, the core focuses on two major taxes: LVIT and Enterprise Income Tax (EIT). In the field of LVIT, disputes mainly concentrate on key issues such as the applicable boundary for the connection of old and new policies, the distinction standard between liquidation scope and remaining property sales, the cost allocation rules for underground parking spaces, the litigability of the Land Value Increment Tax Liquidation Audit Notice, and the legality of service procedures. In the field of EIT, disputes mostly revolve around tax administration issues such as cost deduction disputes caused by non-compliant invoices, the determination of whether the duplicate listing of development costs constitutes tax evasion, and the applicable conditions for verified collection. Such disputes not only directly affect enterprises' tax burden calculation and operational efficiency but may also trigger chain risks such as administrative penalties, damaged credit, and criminal liability. Therefore, in the complex and dynamic tax regulatory environment, establishing a systematic compliance management system and mastering effective dispute resolution and right relief strategies have become key links for real estate enterprises to protect their legitimate rights and interests and achieve sound operation.

The "Compliance Report on Real Estate Land Value Increment Tax and Enterprise Income Tax (2026)" is a legal research report compiled by Huashui based on its in-depth observation of the real estate industry and in-depth summary of experience in handling LVIT and EIT cases. It aims to observe the administrative and collection trends and policy changes of tax-related cases in the real estate industry, summarize and analyze high-frequency dispute points in LVIT liquidation and EIT combined with cases, and propose professional strategies for tax-related dispute resolution and compliance suggestions, so as to provide useful guidance for real estate enterprises in risk prevention and dispute resolution.

Contents:

I. Economic Data Observation of the Real Estate Sector in 2025

II. Collection and Administration Trends of Key Real Estate Taxes

III. Analysis of Typical Cases Involving Land Appreciation Tax Disputes in Real Estate

IV. Analysis of Typical Cases Involving Enterprise Income Tax Disputes in Real Estate

V. Tax-Related Risk Management and Compliance Recommendations for Real Estate Enterprises