In-Depth Interpretation of the Regulations and Announcement on Tax-Related Information Reporting by Internet Platform Enterprises

To implement the "Regulations on Tax Information Reporting by Internet Platform Enterprises" (hereinafter referred to as the "Regulations"), the State Taxation Administration has issued the "Announcement on Matters Concerning Tax Information Reporting by Internet Platform Enterprises" (hereinafter referred to as the "Announcement"). The interpretation is as follows:

1. What is the background of the Announcement? The Regulations specify the basic requirements for internet platform enterprises to report tax information, authorize the State Taxation Administration to formulate implementation measures, define the specific categories and content of identity and income information, establish data standards for reporting, and address matters related to reporting by overseas internet platform enterprises. To facilitate compliance by internet platform enterprises, the State Taxation Administration issued this Announcement to further clarify operational requirements.

2. What are the main contents of the Announcement? The Announcement provides practical guidance around four aspects: "who reports, what to report, how to report, and consequences of non-compliance," detailing the specific categories, content, requirements, and standards for reporting tax information. The main contents are as follows:

First, regarding "who reports," it lists common types of internet platforms and clarifies the reporting entities for tax information.

Second, regarding "what to report," it specifies the categories, content, and standards for internet platform enterprises to report their basic information, as well as the identity and income information of platform-based operators and practitioners. It also clarifies that operators earning livestreaming-related income must report tax information for online hosts and their collaborators.

Third, regarding "how to report," it details the timelines and channels for submitting basic, identity, and income information; arranges the first reporting after the implementation of the Regulations; and specifies rules for extensions, corrections, and termination of reporting.

Fourth, regarding "consequences of non-compliance," it outlines measures for failure to report or provide tax-related information as required.

3. How should an internet platform enterprise operating multiple platforms report tax information? An enterprise operating multiple platforms must consolidate the basic information of all platforms in the "Internet Platform Enterprise Basic Information Reporting Form" while submitting separate identity and income reporting forms for each platform, including the "Identity Information Reporting Form for Operators and Practitioners Within the Platform" and the "Income Information Reporting Form for Operators and Practitioners Within the Platform."

4. How should internet platform enterprises providing aggregation services for other platforms report tax information?

Aggregation platforms (e.g., ride-hailing aggregation platforms) that integrate service resources (such as goods, services, data) from multiple platforms through technical means and provide users with a unified interface for demand-supply matching or information connectivity must report their basic information and the identity information of platform enterprises within the aggregation platform by completing the "Internet Platform Enterprise Basic Information Reporting Form" and the "Identity Information Reporting Form for Platform Enterprises Within the Aggregation Platform."

Platform enterprises within an aggregation platform must report their basic information, as well as the identity and income information of operators and practitioners within their platforms, by completing the "Internet Platform Enterprise Basic Information Reporting Form," "Identity Information Reporting Form for Operators and Practitioners Within the Platform," and "Income Information Reporting Form for Operators and Practitioners Within the Platform."

5. What is meant by "internet platforms providing infrastructure services for mini-programs and quick apps" under the Announcement? These refer to platforms such as quick app centers and internet mini-program platforms that provide application distribution services including publishing, downloading, and dynamic loading.

6. What are "relevant operating entities" in the basic information of internet platform enterprises? These refer to other market entities involved in platform operations besides the reporting entity, including user management entities, payment settlement entities, marketing entities, content management entities, data operation entities, logistics and warehousing entities, and other operating entities.

Example 1: Platform A is jointly operated by Enterprises A, B, C, and D, with Enterprise A holding the value-added telecommunications business license, Enterprise B responsible for user management, Enterprise C responsible for payment settlement, and Enterprise D responsible for marketing. In this case, Enterprises B, C, and D are relevant operating entities. Reporting entity Enterprise A must include their information in the "relevant operating entities" section when completing the "Internet Platform Enterprise Basic Information Reporting Form."

7. What are "professional service agencies" under the Announcement? These refer to platform-based operators that provide planning, operation, brokerage, training, and other services to other operators and practitioners for online transactions, such as MCN agencies and guild agencies that sign contracts with online hosts or content creators to provide services related to online performances, game displays, audiovisual information services, etc.

8. What delivery, transportation, and household service activities are included? For practitioners engaged in delivery, transportation, household, and other convenience service activities on internet platforms who legally enjoy tax benefits or are not required to pay taxes, internet platform enterprises do not need to report their income information.

Delivery service activities include business activities such as receiving and inspecting customer orders and delivering items to specified locations based on order requirements, such as food delivery, intra-city delivery, and courier delivery. Transportation service activities include business activities such as ride-hailing services, chauffeur services, and freight services provided through internet platforms. Household service activities include business activities such as cleaning, laundry, cooking, repairs, and family care services provided through internet platforms.

9. How should internet platform enterprises report income information when natural persons sell intangible assets through internet platforms?

For income obtained by natural persons through internet platforms by providing others with the use rights of patents, trademarks, copyrights, non-patented technologies, and other licensed rights, internet platform enterprises should report it in the "royalty income" column (Column 27) of the "Income Information Reporting Form for Operators and Practitioners Within the Platform."

For income obtained by natural persons through internet platforms by transferring ownership of patents, trademarks, copyrights, etc., internet platform enterprises should report it in the "income from other online transactions" column (Column 28) of the "Income Information Reporting Form for Operators and Practitioners Within the Platform."

10. How should internet platform enterprises report income information when operators and practitioners within platforms obtain non-monetary economic benefits such as virtual beans or coins on internet platforms?

When users recharge on internet platforms and purchase virtual gifts such as flowers or carnivals to tip operators and practitioners within platforms, who thereby obtain virtual beans or coins that can be withdrawn, traded, or exchanged for goods, these constitute non-monetary economic benefits. Internet platform enterprises should convert them to RMB amounts according to the platform's conversion rules when the non-monetary economic benefits reach the accounts (including platform virtual accounts) of the operators and practitioners within platforms, and report the income information during the reporting period in the month following the end of the quarter.

Example 2: A user recharges ¥10,000 on Platform A operated by Enterprise A on September 1, using the entire amount to purchase flowers and carnivals to tip online host Li. Online host Li obtains 100,000 virtual coins on September 1, which reach his virtual account on Platform A. According to Platform A's conversion rules, Li can withdraw ¥5,000. Li withdraws ¥3,000 on December 1. In this case, Li actually obtained non-monetary economic benefits on September 1, and Enterprise A should report Li's "total income" as ¥5,000 during the October reporting period.

11. What is included in "commissions, service fees, and other fees paid to platform enterprises"? How should internet platform enterprises report them?

Commissions, service fees, and other fees paid to platform enterprises generally include software service fees, information technology service fees, advertising service fees, transaction commissions, etc., obtained by enterprises participating in internet platform operations from operators and practitioners within platforms in relation to their online sales for providing basic technical support, advertising promotion, transaction matching, and other services. Commissions, service fees, and other fees collected by different operating entities of internet platforms should be consolidated and reported by the reporting entity for tax information.

Example 3: Platform A is jointly operated by Enterprises A, B, C, and D, with Enterprise A holding the value-added telecommunications business license. Merchant Li registers a store on Platform A, with total transaction volume of ¥200,000 from July to September. Platform A settles with Li on September 30. According to the agreement, Enterprise B collects basic software service fees based on a certain percentage of the store's transaction volume, Enterprise C collects advertising and promotion service fees based on the store's exposure click-through rate, and Enterprise D collects registration fees for the store's participation in promotional activities. Platform A distributes the store's total transaction volume according to the agreement, paying ¥5,000 to Enterprise B, ¥4,000 to Enterprise C, ¥1,000 to Enterprise D, and ¥190,000 to Li. Enterprise A should report the store's "total income" of ¥200,000 from July to September and the "total commissions and service fees paid to the platform" of ¥10,000 during the October reporting period.

Example 4: A user recharges ¥10,000 on Platform A operated by Enterprise A on September 1, using the entire amount to purchase flowers and carnivals to tip online host Wang. Enterprise A recognizes the full ¥10,000 as income from selling virtual props and credits 100,000 virtual coins (worth ¥5,000 according to the platform's conversion rules) to online host Wang's platform account balance on the same day. In this case, Enterprise A should report Wang's "total income" of ¥5,000 for the third quarter and "total commissions and service fees paid to the platform" of ¥0 during the October reporting period.

12. How should "number of transactions (orders)" be reported?

The number of transactions (orders) refers to the net number of transactions (orders), calculated as the total number of settled transactions (orders) during the current period minus the number of returned orders during the current period. Specifically:

(1) For online goods sales businesses, it should be counted and reported mainly based on the number of "orders" generated by the platform. Multiple items from one store in the same order should be reported as one order; multiple items from multiple stores in a single purchase should be counted and reported based on the number of orders generated by the platform per store. Partial returns of items in the same order do not reduce the number of orders.

(2) For online livestreaming businesses, it should be counted and reported mainly based on the number of "transactions" for which related payments are received. For tipping income, the number of transactions should be counted and reported based on the number of tips from viewers; for income from goods promotion, advertising, etc., the number of transactions should be counted and reported based on the number of actually settled transactions.

(3) For other service businesses, it should be counted and reported mainly based on the number of service orders. Partial refunds for the same service order do not reduce the number of orders.

13. How should internet platform enterprises report tax information when operators or practitioners within platforms register multiple stores (accounts) on the same internet platform?

Internet platform enterprises should report identity information for operators within platforms in multiple rows using the format "name (full name) + unified social credit code (taxpayer identification number) + store (account) name + store (account) unique identifier code"; and report identity information for practitioners within platforms in multiple rows using the format "full name + ID type + ID number + country or region + store (account) name + store (account) unique identifier code."

Internet platform enterprises should report income information for operators within platforms from different stores (accounts) in multiple rows using the format "name (full name) + unified social credit code (taxpayer identification number) + name of internet platform generating income + name of store (account) generating income + unique identifier code of store (account) generating income"; and report income information for practitioners within platforms from different stores (accounts) in multiple rows using the format "full name + ID type + ID number + country or region + name of internet platform generating income + name of store (account) generating income + unique identifier code of store (account) generating income."

14. What are the main channels for internet platform enterprises to report tax information?

Internet platform enterprises can choose their reporting method based on their information system construction, enterprise scale, data volume, etc.: large platforms can achieve automated data reporting through "direct data interface connections," while small and medium-sized platforms can upload and import through the electronic tax bureau.

Direct data interface connection refers to the transmission of tax information to tax authorities through interface connections between enterprise systems and tax information systems; upload and import refers to enterprises processing tax information into data files in standardized formats and uploading them through the electronic tax bureau.

15. How should internet platform enterprises report tax information when online hosts promote goods for operators within online goods sales platforms through livestreaming?

When operators within online goods sales platforms conduct commercial collaborations with online hosts and their collaborators to sell goods, internet platform enterprises should report tax information for operators and practitioners within platforms as required, including information for online store operators, online hosts, and their collaborators.

Example 5: Online host Wang promotes goods for operator Enterprise B on Platform A operated by Enterprise A. Enterprise B's online store achieves transaction volume of ¥100,000 through this livestream. According to the agreement, Enterprise B pays service fees to Platform A for this livestream and pays service income to online host Wang (or his collaborator). Platform A distributes livestream-related income according to the agreement.

Case 1: Online host Wang uses his personal account to host a livestream for Enterprise B on Platform A. Platform A collects service fees and settles with online host Wang and Enterprise B. Enterprise A should report identity and income information for online host Wang and Enterprise B as required.

Case 2: Online host Wang's collaborator, Agency C (e.g., an MCN agency), uses Agency C's account to host a livestream for Enterprise B on Platform A, with Wang appearing in the livestream. Platform A collects service fees and settles with Agency C and Enterprise B. Enterprise A should report identity and income information for Agency C and Enterprise B as required.

Case 3: Online host Wang uses his personal account to host a livestream for Enterprise B on Platform A. Platform A collects service fees and settles with online host Wang, Enterprise B, and Wang's collaborator, Agency C. Enterprise A should report identity and income information for online host Wang, Enterprise B, and Agency C as required.

16. How to report when income is paid to hosts through other platforms? Livestreaming platforms report identity information; payment platforms report income information.

When online livestreaming platform enterprises pay related income to online hosts through other cooperating internet platform enterprises, the online hosts are actually engaged in online transactions through the livestreaming platform and are therefore practitioners within the livestreaming platform; the online hosts also obtain income payments from other internet platforms and are therefore practitioners within those other internet platforms.

If the monetary or non-monetary economic benefits obtained by online hosts are paid directly by the livestreaming platform to the hosts' personal accounts (including virtual accounts on the livestreaming platform), the livestreaming platform enterprise should report the online hosts' identity and income information as required; if the monetary or non-monetary economic benefits obtained by online hosts are paid through other internet platforms, the livestreaming platform enterprise should report the online hosts' identity information as required, and the other internet platform enterprises should report the online hosts' identity and income information as required.

17. How should internet platform enterprises and MCN agencies report tax information when online hosts collaborate with MCN agencies to conduct online livestreaming activities and obtain tipping income?

Internet platform enterprises should report identity and income information for MCN agencies and online hosts as required. MCN agencies that obtain livestreaming-related income through internet platforms and pay livestreaming-related income to online hosts and their collaborators should report tax information for the online hosts and collaborators as required.

Example 6: Online host Liu collaborates with Agency B (an MCN agency) to conduct online livestreaming activities on Platform A operated by Enterprise A, using an account registered under Liu's personal name. The livestream earns ¥2 million in tips during the third quarter.

Case 1: According to the agreement, Platform A pays all livestreaming tips to Agency B, and Agency B pays ¥1 million in livestreaming tips to online host Liu.

Internet platform enterprise Enterprise A should report identity information for online host Liu and identity and income information for Agency B as required, marking Agency B as a "professional service agency." It should also complete the "Relationship Table Between Livestreaming Service Agencies and Online Hosts Within the Platform" to report the relationship between Agency B and online host Liu.

Operator Agency B within the platform should report tax information for online host Liu by completing the "Online Livestreaming Tax Information Reporting Form," entering Liu's identity information in the "online hosts and other natural persons without registration certificates" section, Platform A's name in the "name of internet platform generating income" section, Liu's account name on Platform A in the "name of store (account) generating income" section, Liu's account unique identifier code on Platform A in the "unique identifier code of store (account) generating income" section, and the ¥1 million paid to Liu in the "labor remuneration" column under "online hosts and other natural persons without registration certificates."

Case 2: According to the agreement, Platform A pays all livestreaming tips to Agency B, and Agency B pays ¥1 million in livestreaming tips to online host Liu's collaborator, Enterprise C.

Internet platform enterprise Enterprise A should report identity and income information for Agency B and Liu as in Case 1.

Operator Agency B within the platform should report tax information for Enterprise C by completing the "Online Livestreaming Tax Information Reporting Form," entering Enterprise C's identity information in the "other registered entities and individual businesses" section, Platform A's name in the "name of internet platform generating income" section, Liu's account name on Platform A in the "name of store (account) generating income" section, Liu's account unique identifier code on Platform A in the "unique identifier code of store (account) generating income" section, and the ¥1 million paid to Enterprise C in the "total income" column under "other registered entities and individual businesses."

Case 3: According to the agreement, Platform A pays all livestreaming tips to Agency B, and Agency B pays ¥1 million in livestreaming tips to online host Liu's collaborator, Enterprise C, and ¥800,000 in livestreaming-related income to online host Liu.

Internet platform enterprise Enterprise A should report identity and income information for Agency B and Liu as in Case 1.

Operator Agency B within the platform should report tax information for Enterprise C as in Case 2; it should also report tax information for online host Liu as required by completing the "Online Livestreaming Tax Information Reporting Form," entering Liu's identity information in the "online hosts and other natural persons without registration certificates" section, Platform A's name in the "name of internet platform generating income" section, Liu's account name on Platform A in the "name of store (account) generating income" section, Liu's account unique identifier code on Platform A in the "unique identifier code of store (account) generating income" section, and the ¥800,000 paid to Liu in the "labor remuneration" column under "online hosts and other natural persons without registration certificates."

Case 4: According to the agreement, Platform A pays ¥1.4 million in livestreaming tips to Agency B and ¥600,000 to online host Liu. Agency B pays ¥100,000 in livestreaming-related income to online host Liu as agreed.

Internet platform enterprise Enterprise A should report identity and income information for Agency B and Liu as in Case 1, while also reporting Liu's income information.

Operator Agency B within the platform should report tax information for online host Liu by completing the "Online Livestreaming Tax Information Reporting Form," entering the ¥100,000 paid to Liu in the "labor remuneration" column under "online hosts and other natural persons without registration certificates."

18. How should operators within platforms that obtain livestreaming-related income through internet platforms and are also internet platform enterprises report tax information?

Operators within platforms that are also internet platform enterprises and have already reported tax information for online hosts and their collaborators in accordance with Items 2 and 3 of Article 2 of the Announcement need not report this information again.

19. Do overseas internet platform enterprises need to report identity information for operators and practitioners within platforms located outside China?

Overseas internet platform enterprises should report identity information for operators and practitioners within platforms located in China as required by this Announcement and need not report identity information for those located outside China.

20. How will tax authorities strengthen information confidentiality? They will establish confidentiality systems and technical frameworks in accordance with the law to ensure data security.

Tax authorities have long been strengthening taxpayer information confidentiality, establishing comprehensive systems, mechanisms, and technical frameworks to effectively protect taxpayer data security. The Regulations specify that tax authorities should keep obtained tax information confidential in accordance with the law, establish tax information security management systems in accordance with laws, administrative regulations, and national regulations, implement data security protection responsibilities, and ensure tax information security. After tax information is reported, tax authorities will further improve tax information security management systems, enhance security technical protections, and take measures such as encryption and access control to effectively ensure the security and confidentiality of tax information.