The Golden Tax Phase IV back-tax wave: BeiGene subsidiary pays 446 million yuan

After the market closed on June 26, BeiGene, Ltd. (688235.SH) announced that one of its wholly owned domestic subsidiaries had recently received notice from the local tax authority. The company agreed to make certain adjustments to previously filed tax returns and has reached confirmation with the tax authority. It will pay back taxes and late fees totaling about RMB 446 million as required, equivalent to about 30% of its 2025 net profit.

According to BeiGene's 2025 annual report, the company achieved revenue of RMB 38.225 billion in 2025, up 40.46% year on year; net profit attributable to shareholders reached RMB 1.461 billion, turning from a loss of RMB 4.978 billion to a profit; net profit excluding non-recurring items was RMB 1.420 billion, turning from a loss of RMB 5.379 billion to a profit.

BeiGene said it recently received a notice from the local tax authority on relevant tax matters and made certain adjustments to previous tax filings. It also communicated with the authority on technical determinations and differences between tax and accounting treatment. This matter does not involve administrative penalties, and based on the relevant accounting standards it is not considered a prior-period accounting error; no retrospective adjustment to prior financial data is involved.

The company said the impact is expected to be included in 2026 current-period profit or loss, and the exact effect on net profit will be subject to the audited financial statements. The matter is not expected to have a material adverse impact on the company's financial position, going-concern ability, or normal operations.

Many pharma companies disclosed large back taxes or tax-related adjustments this year

Besides BeiGene, many listed pharma companies have disclosed back-tax payments or tax-related adjustments this year. On May 20, Aier Eye Hospital (300015.SZ) announced that after a self-review of tax-related matters it needed to pay RMB 348 million in taxes and RMB 176 million in late fees, totaling about RMB 524 million.

On January 1, China National Pharmaceutical (600056.SH) announced that its wholly owned subsidiaries Sanyao Pharmaceutical and Kangli Pharmaceutical received tax notices and together need to pay about RMB 65.22 million in taxes and late fees. Sanyao Pharmaceutical must pay RMB 21.4862 million in taxes and RMB 10.7429 million in late fees; Kangli Pharmaceutical must pay RMB 21.2826 million in taxes and RMB 11.7061 million in late fees.

In addition, companies such as Jashitang (002462.SZ), Bluestar Medical (002382.SZ), and Chongyao Holdings (000950.SZ) also issued back-tax announcements.

Frequent back-tax payments may be linked to Golden Tax Phase IV supervision and tax self-inspection

According to incomplete Wind data, as of June 25 at least 80 listed companies had disclosed back-tax or tax-adjustment announcements this year, nearing the full-year total of 89 in 2025; the cumulative amount of taxes, late fees, and fines exceeded RMB 6 billion.

Lawyer Gui Xin, senior partner at Taihe Tai (Shanghai) Law Firm, said the recent back-tax payments by listed pharma companies such as BeiGene and Aier Eye Hospital after annual reports were essentially historical compliance issues — tax incentives, tax-accounting differences, and related-party transactions — that surfaced under the strong supervision of Golden Tax Phase IV, given the industry's high R&D investment and diversified business models. Back-tax payments often happen after annual reports because companies complete final settlements and audits and then proactively conduct tax self-inspections to avoid inspection penalties. It also reflects the natural difference in focus between auditing and tax authorities.

Gui Xin further believes that the recent wave of large back-tax payments, both frequent and much larger than in previous years, stems mainly from the full rollout of Golden Tax Phase IV, which enables data penetration across departments. Coupled with stricter oversight of tax incentives and the implementation of the Value-Added Tax Law, companies are forced to clean up historical tax risks from the past five or even ten years. Listed companies may choose to proactively "clear the mines" and disclose them after annual report audits and annual tax reconciliation in order to avoid high penalties and disclosure risk.

Will the future impact be limited to 2026? Lawyer's view: it may first decline and then normalize

On the question of whether this round of back-tax payments only affects this year or will become normalized, Gui Xin believes the huge back-tax wave is not limited to 2026 alone and can be understood on two levels: the big cluster of payments in 2026 is mainly a one-time concentrated settlement of multi-year historical issues (typically a 3- to 5-year lookback); as proactive self-inspections continue, large retrospective back-tax payments may gradually decrease over the next one to two years.

But routine tax adjustments will still exist for a long time. Golden Tax Phase IV's "data-driven taxation" is seen as permanent infrastructure, and strict oversight of tax incentives (including high-tech enterprise annual reviews and real-time verification of R&D super-deductions) has become the norm. In the future, companies may still have back taxes each year during annual settlements due to policy refinements and related-party pricing adjustments — but the amounts should return to normal levels, and the era of concentrated "sky-high old-bill" settlements will not return.