Tax Rectification Under Semiconductor Policy Compliance: Supplementary Tax Wave and Golden Tax Phase IV
On June 26 after market close, BeiGene (688235.SH) announced that one of its domestic wholly-owned subsidiaries recently received a notice from the local competent tax authority. The company agreed to make certain adjustments to previously submitted tax returns, and has confirmed related tax matters with the competent tax authority. It will pay supplementary taxes and late fees totaling approximately RMB 446 million as required. This amount is about 30% of its 2025 net profit.
According to BeiGene's 2025 annual report, the company achieved operating revenue of RMB 38.225 billion in 2025, up 40.46% year-on-year; net profit attributable to the parent was RMB 1.461 billion, turning from a loss of RMB 4.978 billion to profit; non-recurring net profit was RMB 1.420 billion, turning from a loss of RMB 5.379 billion to profit.
BeiGene told Blue Whale News that the company recently received notice from the local competent tax authority regarding certain tax matters, requiring adjustments to previous tax returns. The company had sufficient and professional communication with the competent tax authority on the technical determination of tax matters and differences in tax and accounting treatment, and will pay the amount as required. This matter does not involve administrative penalties. Based on the judgment of the Accounting Standards for Business Enterprises, the matter does not constitute a prior accounting error and does not require retrospective adjustment of prior financial data.
The company expects this matter to be included in current period profit and loss in 2026, and the specific impact on net profit will be based on the audited financial statements. The company stated that this matter is not expected to have a material adverse effect on the company's financial condition, going concern ability, or normal operations.
In addition to BeiGene, several other pharmaceutical companies also issued supplementary tax or tax adjustment announcements this year. On May 20, Aier Eye Hospital (300015.SZ) announced that after conducting a self-inspection on tax matters in accordance with relevant laws and regulations, it confirmed a need to pay supplementary taxes of RMB 348 million and late fees of RMB 176 million, totaling RMB 524 million.
On January 1, China Medicine (600056.SH) announced that its wholly-owned subsidiaries Sanyang Pharmaceutical and Kangli Pharmaceutical received tax notices requiring total supplementary taxes and late fees of approximately RMB 65.2178 million, of which Sanyang Pharmaceutical paid RMB 21.4862 million in supplementary taxes and RMB 10.7429 million in late fees, and Kangli Pharmaceutical paid RMB 21.2826 million in supplementary taxes and RMB 11.7061 million in late fees.
Additionally, Jiasitang (002462.SZ), Lanfan Medical (002382.SZ), and Chongyao Holdings (000950.SZ) also issued supplementary tax announcements.
According to incomplete statistics from Wind data, as of June 25, at least 80 listed companies have disclosed supplementary tax or tax adjustment announcements this year, approaching the total of 89 in the whole of 2025, involving cumulative supplementary taxes, late fees, and penalties exceeding RMB 6 billion.
Gui Xin, a senior partner at Tahota (Shanghai) Law Firm and initiator of Tianmu Venture Capital Ecosystem, stated that the recent supplementary tax payments by listed pharmaceutical companies such as BeiGene and Aier Eye Hospital after annual reports essentially reflect the centralized exposure of historical compliance issues related to high R&D investment, diverse business models, tax preferences (e.g., high-tech qualifications, R&D super deductions), tax-accounting differences, and related-party transactions under the strong supervision of Golden Tax Phase IV. Supplementary taxes mostly occur after annual reports, on one hand as a compliance choice by companies to conduct active tax self-inspection and avoid investigation penalties after completing annual settlement and auditing; on the other hand, it reflects the difference between auditing focusing on financial truth and taxation focusing on the application of tax law. The lawyer pointed out that supplementary taxes are usually a policy caliber adjustment rather than financial fraud, reflecting the normalization of tax compliance in capital markets and self-correction to remove risks.
Further, Gui believes that the frequent occurrence of huge supplementary tax amounts in the pharmaceutical and other industries this year, far exceeding previous years, is fundamentally due to the full implementation of Golden Tax Phase IV enabling multi-department data penetration, combined with strict supervision of tax preferences and the implementation of the VAT Law, forcing companies to centrally clear historical tax risks from the past five or even ten years. At the same time, listed companies, to avoid high penalties and information disclosure risks, choose to actively remove risks and announce after annual audit and annual settlement. The lawyer stated that this multiple resonance of technology forcing, policy tightening, and active compliance has led to the concentrated outbreak of previously hidden inventory issues in 2026, forming a seemingly sudden surge in supplementary tax.
"Will this round of supplementary tax only affect this year or become a normalized impact?" Regarding this question, Gui said that the huge supplementary taxes are not limited to 2026 alone, but follow a two-layer logic: The large-scale supplementary taxes concentrated in 2026 mainly involve one-time centralized clearance of historical inventory from multiple years (typically 3-5 years back). As active self-inspection progresses, such huge retrospective taxes are expected to gradually decrease in the next 1-2 years. However, normalized tax adjustments will exist long-term. The 'digital tax governance' of Golden Tax Phase IV is permanent infrastructure, and strict supervision of tax preferences (high-tech annual review, real-time review of R&D super deductions) becomes the norm. In the future, companies may still face supplementary taxes in annual settlement due to refined policy calibers and related-party transaction pricing adjustments, but amounts will return to regular levels, no longer showing concentrated massive historical account settlement. Tax compliance will evolve from occasional risk removal to rigid daily operational cost for enterprises.
