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China Opens Public Consultation on Revised Tax Administrative Review Rules

China's tax authority is seeking public comments until September 30, 2026, on a revised version of its tax administrative review rules. Here is what foreign founders operating in China should know about the consultation and how to submit feedback.

China Seeks Public Input on Revised Tax Administrative Review Rules

China's State Taxation Administration (STA) has released a draft revision of the Tax Administrative Review Rules and is inviting comments from the public, including companies operating in China. The draft is formally titled the Tax Administrative Review Rules (Draft for Comment).

For foreign founders running a business in China, administrative review is the formal channel for challenging certain tax-related decisions. The consultation is a chance to review the proposed framework and, if relevant, submit feedback before the deadline.

What the Draft Covers

According to the STA notice, the revision is intended to serve several purposes:

• Strengthen the main channel role of tax administrative review in resolving administrative disputes.
• Protect the lawful rights and interests of taxpayers and fee payers.
• Supervise and support tax authorities in exercising their powers in accordance with the law.

The draft amends the existing Tax Administrative Review Rules, originally published as STA Order No. 21 and later amended by STA Order No. 39 and STA Order No. 44. The STA has not, in this notice, detailed the specific substantive changes contained in the draft. The full draft text and an explanatory drafting note are attached to the official notice for review.

Why This Matters for Foreign Founders

Foreign-invested companies in China interact with tax authorities on matters ranging from registration and invoicing to assessments and penalties. Administrative review procedures set out how a company can formally contest certain tax decisions and what process the tax authority must follow.

Because the draft is still at the consultation stage, it is not yet final law. Companies should treat the current rules as the operative framework until any revised rules are formally adopted and published. Still, the consultation is a useful signal of the direction of travel in China's tax dispute-resolution framework, and the draft text is publicly available for those who want to understand the proposed structure.

Founders with cross-border operations may also want to flag the consultation to local finance or legal advisers, particularly if the company has pending or potential tax disputes. Submitting comments is optional, but the window is open to the public, including foreign-invested enterprises.

How to Submit Comments

The STA has set a comment deadline of September 30, 2026. The notice, dated September 1, 2026, lists two channels for feedback:

1. Online Submission

Visit the STA website at https://www.chinatax.gov.cn. On the homepage main menu, go to the “互动交流 – 意见征集” (Interactive Communication – Opinion Collection) section to submit comments.

2. Postal Submission

Send comments by letter to:

• Addressee: Department of Policies and Regulations, State Taxation Administration
• Address: No. 5 Yangfangdian West Road, Haidian District, Beijing
• Postal code: 100038

The envelope should be marked with the words “税务行政复议规则征求意见” (Tax Administrative Review Rules – Solicitation of Comments).

Documents Published with the Notice

The official notice includes two attachments:

• Attachment 1: Tax Administrative Review Rules (Draft for Comment)
• Attachment 2: Drafting Explanation for the Tax Administrative Review Rules (Draft for Comment)

These attachments contain the proposed text and the STA's explanation of the drafting. Foreign founders who want to understand the proposed procedural details should review the attachments directly on the STA website, as the notice itself does not summarize the individual provisions.

Practical Takeaways for Foreign-Invested Companies

• Note the deadline: Comments must reach the STA by September 30, 2026, through one of the two listed channels.
• Review the draft text: The proposed rules and drafting explanation are publicly available as attachments to the notice.
• No immediate compliance change: The draft is a consultation document, not a final rule. Current procedures remain in force until revised rules are formally issued.
• Consider internal review: Companies with tax assessment or dispute experience may find it useful to compare the draft against their existing internal escalation and dispute procedures.

Next Steps

The consultation runs until the end of September 2026. After the comment period, the STA will review feedback and proceed with the rule-making process. Foreign founders should monitor the STA website for the final version and any accompanying guidance.

This summary is based on information published by the relevant Chinese government website and is general information, not legal or tax advice.

Need help registering or operating a company in China? Foreign founders can contact ChinaMNC on WhatsApp / WeChat at +86 153 1898 8535 for assistance with company registration and ongoing operations in China.