On 20 June 2025, the State Council of the People's Republic of China promulgated the Regulations on Internet Platform Companies'Submission of Tax-related Information (Decree No. 810, hereinafter referred to as the Regulations), which came into effect on the same day. Shortly thereafter, on 26 June 2025, the State Taxation Administration (STA) issued the Announcement on Matters Concerning the Submission of Tax-related Information by Internet Platform Enterprises ([2025] No. 15, hereinafter referred to as Announcement No. 15), and the Announcement on Several Matters Concerning Internet Platform Companies Handling Withholding Declaration and Proxy Declaration for Practitioners on Their Platforms (hereinafter referred to as Announcement No. 16).

These legal instruments are closely aligned with the E-commerce Law of the People's Republic of China (effective since 2019). They accommodate the evolving trends of the global digital economy and address the information asymmetry inherent in the platform economy's dynamic and intangible nature. Collectively, these regulations establish and refine China's tax regulatory framework for the platform-based digital economy. A key step forward in China's tax administration of the digital economy, this new series of rules imposes stricter and clearer compliance obligations and challenges on all platform entities, including overseas cross-border internet platform enterprises.

I. Latest Developments in Platform Tax-Related Information Reporting

With the Regulations and its accompanying administrative announcements now fully in effect, since 1 October 2025, more than 6,000 domestic and overseas platforms have submitted their basic information, while over 4,000 platforms have agreed to report tax-related information of operators and practitioners using their platforms.

Of particular note, on 13 October 2025, international e-commerce platform Amazon officially issued a notice titled “Notice on the Requirements for Internet Platform Companies'Submission of Tax-related Information of the People's Republic of China”, confirming that it will complete its first submission of tax-related information by 31 October 2025, covering data for the third quarter of 2025 of the identities, earnings, and platform charges, among others, of Chinese business operators using the platform.

In addition, other major platforms involving Chinese business operators — including AliExpress, TikTok Shop, Tmall, Taobao, JD, Meituan, and Xiaohongshu (Rednote) — have also issued reminders stating that they will report information about business operators on their platforms to the competent tax authorities in accordance with the Regulations and have opened data-query and verification functions for platform users.

II. Core Requirements of Platform Tax-Related Information Reporting

The new rules primarily affect two categories of players in platform business: internet platforms and the operators and practitioners using those platforms.

1. Entities Responsible for Submission: Internet Platforms

The internet platforms regulated by the new rules refer to e-commerce platform operators as defined under the E-commerce Law of the People's Republic of China, as well as other legal persons or unincorporated organisations that provide profit-making services such as online business venues, transaction matching, and information release for online transaction activities. The scope is broad and mainly includes the following seven categories:

-(A) Online commodity sales platforms;

-(B) Online live streaming platforms;

-(C) Online freight platforms;

-(D) Flexible employment platforms;

-(E) Platforms providing services such as education, healthcare, travel, consulting, training, brokerage, design, performance, advertising, translation, agency, technical services, audio-visual information, gaming and leisure, online literature, video and graphic content generation, online lending, etc.;

-(F) Platforms providing aggregation services for internet platforms;

-(G) Mini-programs, quick apps, etc. that provide profit-making services for operators and practitioners using the platform to engage in online transactions, as well as platforms providing infrastructure services for such mini-programs and quick apps.

For overseas internet platform enterprises, the new rules clearly define the entities responsible for fulfilling the reporting obligations:

• Where an overseas internet platform has established an operating entity within China, and such entity has lawfully obtained a value-added telecommunications business operation permit, the tax-related information shall be submitted by that domestic entity.

• Where none of the operating entities established in China has obtained a value-added telecommunications business operation permit, the domestic operating entity that provides merchant onboarding, store operation, marketing and promotional services for the operators and practitioners using the overseas internet platform shall be responsible for the submission.

• Where an overseas internet platform enterprise has no operating entity established within China, it shall designate a domestic agent to complete the submission of tax-related information.

This provision ensures that, regardless of the operational model adopted by an overseas platform in China, there is always a clearly designated entity responsible for the reporting.

2. Information to Be Submitted: Platform, Platform Operators, and Practitioners

(1) Regular (Quarterly) Reporting

The new rules divide the tax-related information to be submitted by platforms into two major categories: (a) basic information about the platform itself, and (b) identity and income information of operators and practitioners using the platform. “Operators and practitioners” refer to legal persons, unincorporated organisations, or natural persons who provide profit-making services through the internet platform.

The first reporting period shall run from 1 October to 31 October 2025, covering data from July to September 2025; thereafter, reporting shall be conducted on a regular quarterly basis. The information required to be submitted includes:

• Basic information of the platform enterprises: Internet platform companies shall, within 30 days from the later of the date of implementation of the new rules or from the commencement of internet business operations, submit to their competent tax authorities the platform domain name, business type, unified social credit code, and the name of relevant operating entities, among other information.

• Information of operators and practitioners using the platform: Information concerning all operators on the platform (including unregistered individuals) shall be furnished, including identity information, transaction volumes and amounts, and platform charges. However, tax-related information of operators and practitioners prior to the implementation of the Regulations is not required to be submitted by internet platform enterprises.

It should be noted that overseas internet platform enterprises are not required to submit the identity information of their overseas operators and practitioners.

(2) Exemptions

• Where the quarterly cumulative net transaction amount for a single domestic purchaser using the platform does not exceed CNY 5,000, overseas internet platform enterprises may for now be exempt from submitting the income information of overseas operators and practitioners who sell services or intangible assets to that purchaser.

• For practitioners engaged in public convenience services such as delivery, transportation, and housekeeping who are eligible for tax incentives or exempt from taxation pursuant to law, internet platform enterprises are not required to submit their income information.

• Where internet platform enterprises have already submitted tax-related information when handling withholding declarations or proxy declarations for operators and practitioners pursuant to the relevant provisions, such information need not be resubmitted.

• Tax-related information generated before the implementation of the Regulations does not need to be retroactively reported by the platform.

(3) Special Circumstances

Where a store or business on an internet platform has been changed or deregistered by the time of the submission, the platform shall still submit data of the store or business for the relevant data submission period that falls, respectively, before and after the change, or prior to deregistration. Furthermore, the platform must truthfully submit all transaction information and may not exclude or select income data at its own discretion.

For overseas platforms, where an operator is registered in China, its relevant information shall still fall within the purview of China's tax-related information reporting, even if the operator's sales occur only overseas.

In addition, when non-natural-person operators on the platform obtain live streaming-related income through the internet platform and make payments to online streamers or their partners, the platform must submit to the competent tax authority the identity and income information of those streamers and partners.

(4) Legal Liability

Failure to submit tax-related information as required, concealment, false reporting, omission, or inaccuracies resulting from the platform's fault, as well as refusal to submit information, shall be subject to orders for rectification within a specified period, fines ranging from CNY 20,000 to CNY 500,000, and suspension of business operations for rectification, and may also result in inclusion in the tax and fee payment credit evaluation system and public disclosure to society.

3. Key Tax Issue of Practitioners Using the Platform

The Announcement No. 16 clarifies the matters concerning platforms handling withholding declarations and proxy declarations for practitioners. On one hand, it specifies the application of the new policies; on the other hand, it seeks to reduce the compliance burden on platforms. The detailed arrangements are as follows:

• Optimization of the individual income tax withholding and prepayment mechanism: Platform enterprises are permitted to apply the cumulative withholding method to calculate and prepay taxes on practitioners'income from personal services, with a monthly deduction of CNY 5,000 and a progressive withholding rate.

• Clarification of VAT and surtax proxy declaration rules: Practitioners may enjoy VAT exemption policies applicable to small-scale taxpayers whose monthly sales do not exceed CNY 100,000. For practitioners whose cumulative service income exceeds CNY 5 million within 12 consecutive months, the platform shall guide them to register as market entities in accordance with the law and to declare and pay taxes independently.

• Clarification of conditions for pre-tax deduction under the enterprise income tax: Where the platform has duly handled individual income tax withholding declarations and VAT and surtax proxy declarations for practitioners and has completed tax payment, it may deduct the remuneration paid to practitioners before tax on the basis of relevant declaration forms and tax payment certificates.

• Avoidance of duplicate reporting: Where the internet platform enterprise has already handled withholding or proxy declarations for practitioners, it is not required to resubmit practitioner information.

III. International Trends in Tax-Related Information Reporting and Cross-Border E-commerce Platform Regulation

Not only in China, strengthening tax administration in the digital economy has become a broad consensus worldwide. Countries and international organisations are actively advancing cross-border information-sharing mechanisms to effectively address challenges such as base erosion and profit shifting brought about by the digital economy.

Taking the European Union as an example, in 2023, the Directive on Administrative Cooperation, Seventh Amendment (DAC7) came into effect, requiring that, regardless of whether a platform is established within or outside the EU, if it facilitates transactions occurring within the EU, it must fulfil its reporting obligations by submitting tax-related information of platform users to the tax authorities of member states. In 2024, the Central Electronic System of Payment Information (CESOP) formally entered into force. Under this system, European payment institutions are required to report all relevant transactions to the tax authorities of member states whenever a seller's cross-border receipts exceed 25 transactions in a single quarter. When sales and payment amounts do not match, the system automatically generates tax audit alerts.

In addition, Australia, the United Kingdom, and the United States, among other countries, have also introduced their own information reporting requirements for digital platforms. Although the details of each jurisdiction's legislation differ, their core objectives remain consistent: to dismantle information barriers, enhance tax transparency, and combat tax evasion.

Through a combination of multilateral cooperation and domestic legislation, the international community is gradually building a global regulatory network for tax-related information reporting by digital platforms. The introduction of China's new rules constitutes an important part of this global trend.

IV. Implications and Responses for Overseas Cross-Border E-commerce Platforms

The implementation of China's new regulations represents, for overseas cross-border e-commerce platforms, not only an increase in compliance costs, but also a great challenge to their existing operational models, data management systems, and risk control frameworks. At the same time, it also brings new opportunities for standardised and sustainable growth.

1. Impacts on Overseas Internet Platform Enterprises

(1) Data Transmission Compliance

During their operations in China, overseas platforms collect tax-related information, particularly sensitive data involving the identity and transactions of domestic operators and practitioners. The storage, processing, and transmission of such data to overseas parent entities must strictly comply with China's Cybersecurity Law, Data Security Law, and Personal Information Protection Law, especially the provisions governing cross-border data transfer security and personal information protection. When platforms submit tax-related information, alongside meeting China's tax reporting requirements, they must assess the data protection regulations of the jurisdictions where their headquarters are located and prudently address the compliance challenges of cross-border data transfers.

(2) Verification Obligations and Legal Liability for Business Authenticity

The new regulations require platforms to ensure that business activities are genuine, not merely carry out formal reviews. If a platform commits errors or fails to comply with such requirement during the information reporting process, it will be held liable and subject to fines, suspension for rectification, and potential inclusion in the tax and fee payment credit evaluation system, among others. However, a platform that has duly fulfilled its information verification obligations and properly verified information won't be held responsible for inaccuracies or falsifications that arise due to any fault of operators or practitioners thereon.

(3) Coordination of Multi-Jurisdictional Reporting Obligations

A globally operating cross-border e-commerce platform must simultaneously comply with divergent reporting regimes in China, the European Union, and other jurisdictions. These frameworks may differ in reporting content, data format, frequency, and even the definition of the reporting entity or tax-related subject. To mitigate compliance risks such as duplicate submissions, inconsistencies, or omissions arising from differing standards or poor system interoperability, platforms are advised to establish a unified yet flexible data governance framework and technical system capable of accommodating multi-jurisdictional reporting requirements.

2. Response Strategies and Recommendations

In view of the challenges brought by the new regulations, overseas cross-border e-commerce platforms should adopt proactive and forward-looking compliance strategies as follows:

(1) Establish Dedicated Compliance Teams and Internal Control Systems

Form a specialised compliance team composed of legal, tax, and technical experts to conduct in-depth research on the new regulations and their accompanying announcements. Develop and improve internal control procedures, clearly defining the responsibilities of each department in the collection, processing, and submission of tax-related information, so as to ensure the authenticity, accuracy, and completeness of data reporting.

(2) Evaluate and Upgrade Data Management and Technical Systems

Conduct a comprehensive assessment of existing data management systems to identify gaps between current practices and the new regulatory requirements, and formulate a detailed technical enhancement and system upgrade plan to ensure full compliance.

(3) Handle Cross-border Data Transfers Prudently

For the cross-border transfer of personal information and important data related to individuals and entities within China, platforms must strictly comply with China's data security laws and regulations, including conducting prior data export security assessments and ensuring full alignment with personal information protection requirements. Where feasible, platforms may consider establishing local data centres within China for onshore data storage and processing, thereby reducing compliance risks associated with cross-border data transfers.

(4) Enhance Collaboration with Domestic Agents or Operating Entities

Where reporting obligations are fulfilled through a domestic agent or operating entity, the overseas platform should enter into a clear and comprehensive legal agreement with such an entity, setting out the rights, obligations, and liability-sharing mechanisms between both parties in detail.

(5) Closely Monitor Policy Developments and International Trends

Continuously follow the latest guidance, interpretations, and implementation updates issued by the Chinese tax authorities, while also keeping track of evolving international tax information reporting frameworks. Stay informed of the latest industry practices and adjust compliance strategies in a timely manner to align with both domestic and global developments.

The promulgation of the Regulations and its two accompanying administrative announcements presents a comprehensive and far-reaching compliance challenge for cross-border e-commerce platforms, covering legal, technical, operational, and strategic aspects.

Overseas platforms should take proactive measures to reassess their operational models, invest necessary resources in system upgrades and process re-engineering, and ensure full compliance with China's data protection and tax laws, as well as those of other relevant jurisdictions. By establishing a rigorous and efficient compliance framework, platforms can not only mitigate potential legal risks but also seize new opportunities for growth in an increasingly regulated digital economy, achieving sustainable long-term development.