As of July 2, 108 A-share listed companies had issued announcements regarding back taxes for the first half of 2026, totaling 9.641 billion yuan. Both the number of companies and the total amount of back taxes paid have already exceeded the figures for the entire year of 2025—including a one-time payment of 1.41 billion yuan by Beidahuang, a payment of 524 million yuan by Aier Eye Hospital, and three separate payments totaling nearly 120 million yuan within half a year by Enjet Co., Ltd., a leading manufacturer of lithium-ion battery separators.

The hundreds of millions in back taxes aren’t the main issue. The key point is this: despite having full-fledged finance teams and auditing firms, these companies still revealed a large number of problems during their tax self-inspections. If even publicly listed companies cannot withstand the thorough scrutiny of this round of ”data-driven tax administration,” then the tax compliance pressure on cross-border e-commerce sellers—who face issues such as uninvoiced purchases, complex payment chains, and multiple entities and platforms—will only intensify.

This article breaks down the three underlying reasons behind this wave of tax reassessments, reviews two typical cases, and outlines four self-assessment steps that cross-border e-commerce companies must take.

I. 108 Companies, 9.6 Billion: Three Signals Behind the Numbers

Sign #1: The scale is unprecedented. 

Not only did the total amount exceed that of the entire year of 2025, but in June alone, 34 companies announced tax backpayments in quick succession. On average, one listed company announced a tax backpayment every two days. There were 21 instances of large-scale tax backpayments exceeding 100 million yuan each, contributing a combined total of over 7 billion yuan, accounting for 77% of the total amount.

Sign #2: The industry has an extremely broad scope. 

Pharmaceuticals and Biotechnology (20 companies, totaling 1.753 billion yuan), Machinery and Equipment, Power Equipment, Commerce and Retail, Electronics, Basic Chemicals, Agriculture, Animal Husbandry, and Fisheries—virtually all major industries are on the back-tax list. No industry is ”immune.”

Sign No. 3: The vast majority of cases involve voluntary self-assessment and back payments, rather than being the result of tax audits. 

Almost all announcements state ”based on a self-inspection” and ”no administrative penalties.” This indicates that these issues were not uncovered during a surprise audit by the tax authorities, but rather that the companies proactively identified historical tax arrears themselves by cross-checking their data following the launch of the Golden Tax Phase IV system.

II. Two Typical Cases: Two Typical Pathways in the Wave of Back Tax Payments

Beidahuang: The Cost of Misinterpreting Policy—1.41 Billion Yuan

On June 22, Beidahuang announced that it had received a notice from the tax authorities requiring the company to pay 1.024 billion yuan in corporate income tax for the period from 2021 to 2025, plus 386 million yuan in late payment penalties, for a total of 1.41 billion yuan. This expense will directly reduce the company’s 2026 net profit by 1.41 billion yuan—while Beidahuang’s net profit attributable to parent company shareholders for the full year of 2025 was only 1.166 billion yuan. Following the announcement, the stock price hit the daily trading limit down for two consecutive trading days, with a cumulative decline of 22.42% over three trading days.

Where does the problem stem from? It’s not tax evasion or tax avoidance, but ratherDifferences in Interpretation of the Scope of Application of Tax Incentive PoliciesThe

Beidahuang’s 16 agricultural subsidiaries are engaged in land contracting operations. Under current tax law, state-owned farms are eligible for corporate income tax exemptions on income from contracting land to ”their own employees” for cultivation. However, tax authorities have determined that some of Beidahuang’s contracting parties are ”non-employee family farms”—meaning that this portion of the income does not meet the conditions for the tax exemption and is subject to corporate income tax as required.

A dispute over the distinction between ”employees” and ”non-employees” has cost 1.41 billion yuan. The assessment covers a five-year period (2021–2025), with late payment penalties accruing at a rate of 0.05‰ per day; the approximately 37.7% in back taxes illustrates the length of the delinquency.

Key Lesson: Policy application is not a matter of ”whatever I think is reasonable”; it requires a clear legal basis and confirmation of the tax treatment. This is especially true in gray areas—if a ruling is later revised, the amount of back taxes owed could exceed a year’s profit.

Enjet Co., Ltd.: Three Times in Half a Year—Once the Momentum of Self-Inspection Gains Traction, Past Shortcomings Have Nowhere to Hide

Enjet Co., Ltd., the global leader in lithium-ion battery separators, issued three announcements regarding tax payments by its subsidiaries in January, May, and June 2026, involving its subsidiaries Wuxi Enjet, Jiangxi Tongrui, and Zhuhai Enjet—three core production bases. The total back taxes amounted to approximately 99.85 million yuan, with late payment penalties of approximately 19.87 million yuan, for a combined total of nearly 120 million yuan.

All three tax payments were marked as ”self-assessment.” One of these was calculated retroactively based on late payment penalties, with the corresponding tax delinquency period spanning approximately two years—indicating that these were not operational errors from the current period, but rather historical issues from the previous two years that were identified during a comprehensive review as part of the Golden Tax Phase IV data comparison.

The case of Enjet Co., Ltd. serves as a broader cautionary tale: an industry leader with a market capitalization exceeding 60 billion yuan discovered additional issues during its second and third rounds of self-inspections after completing the first round. Self-inspections are not a ”one-time” process; the more thoroughly data systems are examined, the more problems are uncovered.

Key Lesson: Data cross-checks under Phase IV of the Golden Tax System are ongoing and cumulative. Simply conducting a self-inspection today does not mean all issues have been resolved; cross-checks of historical data will continuously update the risk list as the system’s data sources expand.

III. The Three Underlying Drivers of the Tax Payment Surge

First, Phase IV of the Golden Tax Project has evolved from ”tax administration based on invoices” to ”tax administration based on data.” 

This is the fundamental reason. In the past, tax audits relied primarily on the invoice chain—as long as the invoices matched up and the ledgers were clearly recorded, the audit was generally passed. The Fourth Phase of the Golden Tax Project has integrated data from multiple departments, including tax authorities, banks, industry and commerce, customs, social security, and utilities, enabling real-time cross-checking. Your invoice data, bank transaction records, export customs declaration records, number of employees covered by social security, and electricity consumption—data that was previously scattered across different systems—can now be automatically cross-checked on a single risk ledger. Wherever there is a discrepancy, an alert is generated.

Second, the annual tax settlement and annual report audit are triggered simultaneously. 

The deadline for corporate income tax annual settlement is at the end of May, and the annual report audits wrap up in June—this is a fixed timeframe. Compounded by the fact that the Golden Tax Phase IV system issued a concentrated wave of tax risk notices in the first half of the year, a large number of companies identified discrepancies during the audit and annual settlement processes and proactively disclosed them.

Third, the consequences of conducting a self-inspection versus being audited are worlds apart. 

At this stage, the vast majority of tax payments are labeled as ”self-inspection” and ”no administrative penalties.” The consequences of a self-inspection-based tax payment are: payment of the back taxes plus a daily late payment penalty of 0.05‰; there are no administrative fines, and it does not affect the company’s qualifications, financing, or listing status. However, once a case transitions from ”self-inspection” to ”official audit and case filing,” the consequences are: full payment of back taxes + late payment penalties + fines. This may affect eligibility for tax incentives such as high-tech enterprise status and could even trigger criminal liability. This significant disparity is driving companies to shift from ”passively waiting” to ”proactively rectifying” their tax compliance.

IV. Three Direct Warnings for Cross-Border E-Commerce

Listed companies are facing a ”data-driven” tax compliance audit, while the data environment for cross-border e-commerce sellers is far more vulnerable than that of listed companies:

Warning 1: Purchasing Without Invoices—The Biggest Time Bomb for Cross-Border E-Commerce. 

While policy discrepancies are the main reason listed companies have to pay back taxes, cross-border e-commerce faces an additional layer of tax risk: a large number of sellers cannot obtain special VAT invoices from their suppliers, so they export goods by paying on behalf of others or ship goods purchased without invoices. Under the framework of ”data-driven tax administration,” your customs declaration data, platform sales revenue, and bank payment records will inevitably be cross-checked within the system. From a data perspective, uninvoiced purchases represent a glaring gap—it’s not a question of whether they will be exposed, but when.

Warning 2: Multiple Entities, Multiple Platforms—The More Severe the Data Discontinuity, the Greater the Risk.

 A typical cross-border e-commerce business model consists of one owner, multiple stores, multiple legal entities (domestic company + Hong Kong company + U.S. company), and multiple payment channels. Each additional layer of legal entities creates another layer of data fragmentation. Even publicly traded companies—which operate as a single legal entity with a single set of financial records—still require three rounds of self-inspections to complete their compliance checks. If the multi-entity structure of cross-border e-commerce lacks unified financial and tax data integration across all levels, it will be like a sieve in the face of the “Golden Tax Phase IV” initiative.

Warning 3: The larger the scale, the more dangerous it is if past debts remain unresolved. 

Beidahuang’s five-year retroactive audit and Enjet’s three rounds of self-inspections—the retroactive capabilities of the Golden Tax Phase IV system aren’t about this year, but about the past. Records of uninvoiced purchases, payments through private accounts, and zero-declaration filings from cross-border e-commerce businesses over the past three or five years will not disappear from the data system—not a single one.

If you have any needs, please feel free to contact Qicaiying, and we will tailor a solution just for you:Cell phone: 18676749275 ｜ WeChat: qcygscszk

V. Four Self-Assessment Steps for Cross-Border E-Commerce Tax Compliance

Drawing on the lessons learned from this wave of tax back payments by publicly listed companies, cross-border e-commerce sellers should not simply ”wait and see” at this time, but rather proactively conduct a systematic self-audit.

First, review of invoice compliance on the procurement side. 

Review the invoicing qualifications of all suppliers on a case-by-case basis. For purchases eligible for special tax invoices, ensure that the invoice information matches the customs declaration forms and platform sales records. For purchases where special tax invoices cannot be obtained, assess whether alternative channels are available or whether the procurement model can be adjusted within the compliance framework.

Second, end-to-end matching on the revenue side. 

Platform sales revenue, third-party payment records, and amounts credited to corporate accounts—do these three lines correspond one-to-one? Where do the discrepancies lie? Did the payment chain pass through any personal accounts or offshore accounts? Every node in the chain must be traceable within the tax system.

Third, verification of financial boundaries among multiple entities. 

Are there clear contractual bases and financial records for the flow of funds, movement of goods, and allocation of expenses among domestic entities, Hong Kong companies, and U.S. companies? In multi-entity structures without separate accounting, related-party transactions and profit shifting are the high-risk areas most likely to be reclassified and subject to back taxes under the “Golden Tax Phase IV” system’s穿透审查.

Fourth, proactively address historical issues.

The core logic behind this wave of back-tax payments by publicly listed companies is ”leniency for self-reporting, strictness for audits.” Cross-border e-commerce sellers should adopt a consistent strategy: before the system issues a warning, proactively review the past three years for any historical issues—such as unreported income, purchases without invoices, or omitted tax types—and prioritize resolving the “hard gaps” that would be directly exposed through cross-checking of data.

Listed companies can withstand the impact of 1.41 billion yuan in back taxes, but cross-border e-commerce sellers will most likely be unable to do so. However, you don’t have to wait for that impact to hit—the experience of 108 listed companies makes it clear: in the face of the Golden Tax Phase IV initiative, self-inspection is the most cost-effective path to compliance.

If your company meets any of the following criteria—long-term lack of invoices on the procurement side, payment flows passing through multiple layers of accounts, blurred financial boundaries between multiple entities, or no tax compliance audits conducted in the past three years—we recommend that you proactively conduct a full-chain compliance assessment starting now.

Qicaiying Group | Cross-Border E-Commerce Financial and Tax Compliance Service Provider

Specializing in end-to-end financial and tax compliance for cross-border e-commerce companies: compliance reviews of input VAT invoices, reconciliation of export revenue with cash flow, compliance assessments of related-party transactions in multi-entity structures, and historical tax risk assessments and remediation plans.

Cell phone: 18676749275 ｜ WeChat: qcygscszk

Enterprise Finance Group

Founded in 2015 and headquartered in Shenzhen, Qicaiying Group is a leading provider of corporate services and tax compliance solutions in China.

The Group is deeply committed to providing services across the entire corporate lifecycle. Its core business areas include: business registration, bookkeeping services, tax compliance, overseas company registration (Hong Kong, the U.S., Singapore, Mexico, etc.), cross-border structuring, outbound direct investment (ODI) filing, overseas tax planning, bank account opening assistance, and identity planning.

Over the past decade, Qicaiying has served more than 10,000 corporate clients and has accumulated solid practical experience in key areas such as corporate structuring in Hong Kong and overseas, cross-border tax and financial compliance, and corporate accounting management. The Group boasts a team of seasoned financial and tax advisors who closely monitor changes in domestic and international tax systems and regulatory trends, providing clients with one-stop solutions ranging from structural planning to implementation.