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Interpretation of the Announcement on Optimizing Advance Payment of Enterprise Income Tax by the State Taxation Administ

Published On:2025-09-16 10:56:27
To implement the Enterprise Income Tax Law of the People's Republic of China and related tax policies, further reduce the tax compliance burden for enterprises, and optimize declaration items, the State Taxation Administration has issued the Announcement on Optimizing Advance Payment of Enterprise Income Tax (hereinafter referred to as the "Announcement"). The interpretation is as follows:
I.Background‌

In 2024, to implement the Notice of the State Council on Issuing the "Action Plan for Promoting Large-Scale Equipment Updating and Consumer Goods Trade-In" (Guo Fa [2024] No. 7), the Ministry of Finance and the State Taxation Administration jointly issued the Announcement on Enterprise Income Tax Policies for Digital and Intelligent Upgrading of Energy Conservation, Water Conservation, Environmental Protection, and Workplace Safety Specialized Equipment (2024 No. 9), further enhancing the preferential policies for the tax credit on specialized equipment (hereinafter referred to as the "Specialized Equipment Tax Credit Policy"). To facilitate taxpayers in enjoying these benefits and in response to their feedback and suggestions regarding advance payment of enterprise income tax, the State Taxation Administration issued the Announcement, clarifying the requirements for claiming the tax credit during advance payment and the declaration procedures for export-related matters, among other specific issues. Additionally, the Monthly (Quarterly) Advance Payment of Enterprise Income Tax Return (Form A) was revised accordingly.
‌II. Main Content
(1) Clarification on the Implementation of the Specialized Equipment Tax Credit Policy‌
According to the Announcement of the State Taxation Administration on Issuing the Revised "Measures for Handling Enterprise Income Tax Preferential Policies" (2018 No. 23), the specialized equipment tax credit policy was to be claimed during the final settlement filing. To implement the Joint Announcement of the Ministry of Finance and the State Taxation Administration on Enterprise Income Tax Policies for Digital and Intelligent Upgrading of Energy Conservation, Water Conservation, Environmental Protection, and Workplace Safety Specialized Equipment (2024 No. 9), facilitate taxpayers' access to the tax credit, and fully release policy benefits, the Announcement clarifies that taxpayers may now voluntarily choose to claim the specialized equipment tax credit during the advance payment filing, based on their operational circumstances. Those who do not claim the credit during advance payment may still do so during the final settlement filing.
(2) Clarification on Export Enterprises' Declaration Requirements‌
To further standardize the advance payment filing management of export enterprises and enhance compliance, the Announcement specifies the advance payment filing requirements for export enterprises.
Reiteration of Tax Declaration Obligations for Export Enterprises.‌
▪ Enterprises engaged in the production and sale of exported goods must calculate and declare the income from such exports for enterprise income tax purposes.
▪ For self-operated exports, the income corresponding to the export of goods produced or sold by the enterprise must be included in the operating revenue for declaration.
▪ For consignment exports, the income corresponding to the export of goods consigned by the enterprise must be included in the operating revenue for declaration.
▪ In addition to declaring such income as part of operating revenue, export enterprises must also provide detailed information about these two types of export income.
Requirements for Export Agency Businesses.‌
▪ Enterprises engaged in export agency services must include their agency fee income in operating revenue and declare the details.
▪ To standardize enterprise income tax management for export agency businesses (including those operating through market procurement trade, foreign trade comprehensive services, etc.), the Announcement requires these enterprises to submit the Summary of Entrusted Export Cases by Export Agency Enterprises during advance payment filing. This form must include the basic information of the consignor and the export amount.
▪ For goods involving multiple export stages, the actual consignor's (i.e., the genuine production/seller of the goods, typically a domestic entity) basic information and export amount must be reported.
▪ If the reported party is a non-genuine consignor (e.g., a customs broker, freight forwarder) or a non-domestic entity, the transaction will be treated as a self-operated export, and the reporting enterprise will be responsible for declaring and paying the corresponding enterprise income tax.
‌Case 1: Export Agency Business of Company A‌
Company A engages in export agency services, accepting Company B's consignment to export goods produced by Company B, involving multiple customs export declarations totaling RMB 10 million, with an agency fee of RMB 100,000. The advance payment filing requirements are as follows:
‌Company A's Declaration Obligations.‌
▪ Must declare operating revenue of RMB 100,000, consisting entirely of export agency fee income.
▪ Must complete the Summary of Entrusted Export Cases by Export Agency Enterprises by itemizing:
▪ Customs export declaration numbers for Company B's consignments.
▪ Company B's name (as the actual consignor).
▪ Company B's taxpayer identification number (Unified Social Credit Code).
▪ Corresponding export amounts for each consignment.
▪ The total export amount attributable to Company B must sum to RMB 10 million.
‌Company B's Declaration Obligations‌
▪ Must declare operating revenue of RMB 10 million, consisting entirely of consignment export income.
Case 2: Export Agency Business of Company C‌
Company C engages in export agency services, accepting Company D's consignment to export goods that were originally consigned by Company D to Company E. The transaction involves a single customs export declaration totaling RMB 10 million, with Company C charging an agency fee of RMB 100,000. Company D charges Company E an agency fee of RMB 120,000. Company E is the actual domestic manufacturer and seller (the genuine consignor) of the exported goods. The advance payment filing requirements are as follows:
1.Company C's Declaration Obligations‌
Must declare operating revenue of RMB 100,000, consisting entirely of export agency fee income.
Must complete the Summary of Entrusted Export Cases by Export Agency Enterprises by:
Providing the customs export declaration number.
Entering Company E's name (as the actual consignor).
Entering Company E's taxpayer identification number (Unified Social Credit Code).
Declaring the corresponding export amount of RMB 10 million.
2.Company D's Declaration Obligations‌
Must declare operating revenue of RMB 120,000 (no need to specify "export agency fee income" or submit the Summary of Entrusted Export Cases).
3.Company E's Declaration Obligations‌
Must declare operating revenue of RMB 10 million, consisting entirely of consignment export income.
Penalty Clause:‌
If Company C fails to report Company E's export details in the Summary of Entrusted Export Cases, the transaction will be treated as a self-operated export, and Company C will be responsible for declaring and paying the corresponding enterprise income tax on the RMB 10 million export amount.
(3.)Optimization and Improvement of the Monthly/Quarterly Advance Payment Filing Form for Enterprise Income Tax (Class A)‌
In light of the refined policy implementation guidelines and the feedback/comments received from taxpayers, the Monthly/Quarterly Advance Payment Filing Form for Enterprise Income Tax (Class A) will be revised accordingly.
1.‌Revision of the Monthly/Quarterly Advance Payment Filing Form for Enterprise Income Tax (Class A) (A200000)‌
1.)‌Addition of Supplementary Reporting Items‌
New items ("Employee Compensation" and "Export Methods") are added to the Information on Preferential and Supplementary Matters. Taxpayers involved in related activities must accurately report these details. Other supplementary items should be reported based on the Enterprise Income Tax Filing Item Catalog.
2.)‌Adjustments to Advance Tax Calculation Section‌
Aligning with the annual tax return optimization framework, new items ("Selling Expenses" and "Other Income") are incorporated to reflect updated financial statement formats.
Under "Operating Revenue," sub-items ("Self-Export Income," "Consignment Export Income," and "Export Agency Fee Income") are added for export-related businesses.
Under "Investment Income," detailed line items are introduced to report specific matters (e.g., equity disposal gains) and amounts, as per the Filing Item Catalog.
3.)‌Addition of "Tax Credit Amount" Item‌
A new field is added for enterprises eligible for special equipment tax credits to voluntarily report during advance filings.
4.)‌Addition of "Income from Unfinished Product Sales" Item‌
A dedicated field is added for real estate developers to clarify reporting requirements for pre-sale income from uncompleted development projects.
2.‌Revision of the Enterprise Income Tax Allocation Form for Consolidated Tax Filings by Head and Branch Offices (A202000)‌
1.)‌Adjustment to Tax Allocation Calculation Method‌
The tax allocation method previously used in the final settlement filing will now be extended to the advance payment filing stage. Specifically:
The enterprise must first allocate the total income tax payable up to the current month (quarter) among all branches.
The head office and each branch will then deduct the tax amounts they have already prepaid based on their respective allocations.
The resulting difference (either a tax refund or additional payment) for the current month (quarter) will be calculated accordingly.
‌Example Illustration:‌(Insert a numerical example here to demonstrate the calculation process, e.g., showing how total tax is allocated between head office and branches, how prepaid taxes are offset, and the final settlement amount.)
Case Study: A Company's Consolidated Tax Filing Allocation Adjustment.‌
Company Background‌:A Company was established in Beijing in 2024 and does not qualify as a small-scale low-profit enterprise.
It operates three branches:Branch B‌ in Shandong Province;Branch C‌ in Shaanxi Province;Branch D‌ in Tianjin Municipality;Branch Closure;‌Branch D in Tianjin was deregistered in September 2025.Tax Filing Compliance,‌The head office and all branches completed the consolidated tax filing registration accurately and on time as required.
Allocation Ratio Adjustments.‌Q1 2025 Advance Payment Filing:‌Incorrect allocation ratio,Branch B: 10%;Branch C: 40%;Branch D: 50%.Q2 2025 Advance Payment Filing:‌Corrected ratios identified,Branch C: 30%;Branch D: 60%.
‌A Company's 2025 Quarterly Profit and Tax Allocation Report‌ quarterly Profit Summary:‌
‌Q1 2025:‌ Actual profit of RMB 4 million
‌Q2 2025 (cumulative):‌ Actual profit of RMB 7 million
‌Q3 2025 (cumulative):‌ Actual profit of RMB 13 million
‌Q4 2025 (cumulative):‌ Actual profit of RMB 12 million
The company does not qualify for any enterprise income tax preferential policies.
‌Tax Payment and Allocation Details‌
‌A Company's Quarterly Tax Calculation and Branch Allocation Report (2025)‌

‌Q1 Advance Payment Filing‌
‌Allocation Ratios:‌
Branch B: 10%
Branch C: 40%
Branch D: 50%
‌Calculation Basis:‌

Total Q1 profit: RMB 4 million
Tax rate: 25% (standard rate)
‌Example:‌
Total tax payable: RMB 1 million (4M × 25%)
Branch B's share: RMB 100,000 (1M × 10%)
Branch C's share: RMB 400,000
Branch D's share: RMB 500,000
‌Q2 Advance Payment Filing (Correction)‌
‌Adjusted Ratios:‌
Branch B: 10%
Branch C: 30%
Branch D: 60%
‌Calculation Basis:‌

Cumulative profit: RMB 7 million (Q1: 4M + Q2: 3M)
‌Adjustment Logic:‌
Recalculate Q1 allocation using new ratios (no retroactive adjustment)
Apply corrected ratios to Q2 only
‌Q3 Advance Payment Filing (Post-Deregistration)‌
‌Revised Ratios:‌
Branch B: 20%
Branch C: 80%
‌Key Notes:‌

Branch D deregistered in September 2025; excluded from Q3 onward
No reallocation of previously paid taxes by Branch D
‌Q4 Advance Payment Filing‌
‌Continuation of Rules:‌
Maintain Q3 ratios (B: 20%, C: 80%)
Cumulative profit: RMB 12 million (Q1-Q4)
‌Example:‌

Q4 profit: RMB -1 million (12M - 13M from Q3)
No tax payable for Q4 due to loss carryforward
Explanation of Consolidated Tax Allocation Calculation Methods‌
General Principle‌
For enterprises filing consolidated taxes, if there are no scenarios such as branch deregistration or inaccurate tax allocation calculations, the results will be identical whether using the original or the new calculation method.
Special Cases Requiring Recalculation‌
However, if either of the following occurs:
Inaccurate tax allocation calculations during prior advance payment periods
Branch deregistration in the current quarter
The new calculation method will employ a full-volume allocation approach to recalculate the annual tax allocation.
Case Example‌
Q2 Adjustment (Discovery of Q1 Error):‌
Incorrect Q1 allocation ratios for Branches C and D (40%/50% vs. correct 30%/60%)
Tax Adjustment Differences:‌
Branch C: RMB 50,000 less under new method
Branch D: RMB 50,000 more under new method
Branch B: No difference (original ratio was correct)
Q3 Adjustment (Post-Deregistration):‌
After Branch D's deregistration, allocation ratios were recalculated (B: 20%, C: 80%)
Tax Adjustment Differences:‌
Branch B: RMB 17,500 less under new method
Branch C: RMB 17,500 more under new method
‌Modification of Form Name and Data Items for Consolidated Tax Allocation‌
‌Form Name Change‌
Original form name: [Previous Form Name]
Revised form name: Enterprise Income Tax Allocation Form for Head Office and Branches under Consolidated Filing
‌Row Items Added‌
"Head Office Allocation"
"Head Office Fiscal Centralized Distribution"
‌Column Items Added‌
"Actual Allocable Income Tax Amount"
"Cumulative Allocated Income Tax Amount"
"Allocation Adjustment for Tax Refund/Payment"
Ⅲ.Implementation Timeline of the Announcement‌
‌Effective Date‌
The Announcement shall take effect from ‌October 1, 2025‌.
‌Application of New Forms‌
‌Monthly Prepayment Enterprises (Accrual-based):‌
Begin using the new forms starting from the ‌September 2025 filing period‌.
‌Quarterly Prepayment Enterprises (Accrual-based):‌
Begin using the new forms starting from the ‌Q3 2025 filing period‌.
‌Source:‌ Qinghai Provincial Taxation Administration, State Taxation Administration.

 
Source: Qinghai Provincial Taxation Bureau, State Taxation Administration
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