Foreword

Tax risks in the pharmaceutical industry are closely intertwined with commercial bribery, presenting the typical industrial characteristic of the interweaving and coexistence of fraudulent invoicing violations and commercial bribery, and boasting distinct industry-specific features. In 2025, regulatory authorities further advanced the anti-corruption work in the pharmaceutical industry in depth, with multiple departments including the Central Commission for Discipline Inspection, the National Health Commission and the State Administration for Market Regulation collaborating to take targeted actions. They explicitly listed commercial bribery as a key crackdown area and adopted a regulatory model of "investigating both bribery and acceptance of bribes and imposing two-way accountability" to continuously investigate and punish illegal and irregular acts in the pharmaceutical industry with a stringent stance. Stock exchanges and the China Securities Regulatory Commission focused on the authenticity and rationality of promotion services provided by listed pharmaceutical enterprises, and built an all-round regulatory defense line through regulatory inquiries and inspections.

As the country ramps up efforts to rectify commercial bribery in the pharmaceutical industry, tax authorities have also continuously intensified the investigation and punishment of tax-related illegal acts committed by pharmaceutical enterprises. In 2025, many listed pharmaceutical enterprises successively issued announcements on large-sum tax supplements; the legal representatives of some pharmaceutical enterprises were legally restricted from leaving the country due to corporate tax arrears; a number of cases involving fraudulent invoicing and tax evasion were exposed one after another. The relevant parties faced tax administrative risks such as making back tax payments, paying late fees and fines, and even had to bear criminal liabilities for the crime of fraudulent invoicing, leading to a marked rise in compliance pressure on the pharmaceutical industry. Against this backdrop, how pharmaceutical enterprises effectively conduct tax compliance in advance to guard against potential tax-related risks, and how to provide effective evidence and make defenses afterwards to respond to erupted tax-related risks have become key issues bearing on the sustainable and healthy development of the industry.

Based on its profound practical experience and in-depth observations in the pharmaceutical industry, the HTS Tax Team has compiled the 2026 Pharmaceutical Industry Tax Compliance Report. By observing the development overview and tax regulatory posture of the pharmaceutical industry in 2025, focusing on tax-related administrative and criminal cases in the industry that year and conducting an in-depth analysis of the causes of fraudulent invoicing risks in the pharmaceutical industry, the report puts forward targeted and operable strategies for resolving and responding to tax-related risks on this basis. It is intended to provide useful insights and practical references for the construction of tax compliance and the high-quality development of the pharmaceutical industry.