Pharmaceutical Tax Make-up Storm: Golden Tax Phase IV Forces Compliance Mine Clearing

On June 26 after market close, BeiGene (688235.SH) announced that its domestic wholly-owned subsidiary received a notice from the local competent tax authority. The company agreed to make certain adjustments to previously filed tax returns and has completed confirmation with the authority, promising to timely pay back taxes and surcharges totaling approximately RMB 446 million. This amount is about 30% of the company's 2025 net profit.

BeiGene's previously disclosed 2025 annual report shows that the company achieved revenue of RMB 38.225 billion in 2025, up 40.46% year-on-year; net profit attributable to parent was RMB 1.461 billion, turning from a loss of RMB 4.978 billion in the prior year; non-recurring net profit was RMB 1.420 billion, also turning profitable from a loss of RMB 5.379 billion.

The company told media that it recently received a notice from the local tax authority regarding related tax matters, making certain adjustments to previously filed tax returns and communicating with the authority on differences in technical identification and tax-accounting treatment. The company will pay the amount as required. This matter does not involve administrative penalties. Based on the accounting standards for business enterprises, the company determined that this event is not a prior-period accounting error and does not require retrospective adjustments to prior financial data.

BeiGene also stated that the impact is expected to be recorded in current-period profit and loss for 2026, with the specific impact on net profit subject to audited financial statements. The matter is not expected to have a material adverse effect on the company's financial condition, ongoing operations, or normal business.

Multiple Pharmaceutical Companies Report Tax Make-up and Adjustments This Year

In addition to BeiGene, several other pharmaceutical companies have disclosed large tax make-up payments this year. For example, 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 the need to pay back taxes of RMB 348 million and surcharges 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 combined back taxes and surcharges of about RMB 65.2178 million. Among them, Sanyang paid back taxes of RMB 21.4862 million and surcharges of RMB 10.7429 million; Kangli paid back taxes of RMB 21.2826 million and surcharges of RMB 11.7061 million.

Additionally, companies such as Jiasitang (002462.SZ), Lanfan Medical (002382.SZ), and Chongyao Holdings (000950.SZ) have also issued tax make-up announcements.

Lawyer Interpretation: Golden Tax Phase IV's Strong Supervision Drives Centralized Clearance of Historical Risks

According to incomplete statistics from Wind data, as of June 25, at least 80 listed companies had disclosed tax make-up or tax adjustment-related announcements this year, approaching the total of 89 for the full year 2025; the cumulative amount involved in back taxes, surcharges, and fines exceeded RMB 6 billion.

A lawyer said that the recent wave of tax make-up by pharmaceutical listed companies like BeiGene and Aier Eye Hospital after reporting annual results is essentially related to the strong supervision of Golden Tax Phase IV. The pharmaceutical industry's high R&D investment, diverse business models, and associated tax incentives (such as high-tech enterprise qualifications, R&D super deduction), tax-accounting differences, and historical compliance issues related to related-party transactions have all come to light. The tax make-up often occurs after the annual report, as companies conduct active tax self-inspection after final settlement and audit to avoid penalties, reflecting the difference in focus: audit emphasizes financial accuracy, while tax emphasizes compliance with tax law.

The lawyer believes that the surge in huge tax make-up payments in the pharmaceutical and other industries this year, far exceeding previous years, is due to the full implementation of Golden Tax Phase IV, which achieves multi-department data penetration, combined with stricter supervision of tax incentives and the implementation of the Value-Added Tax Law. This has forced companies to conduct centralized clearance of historical tax risks spanning the past five or even ten years. To avoid high penalties and disclosure risks, listed companies choose to proactively 'clear mines' and announce after annual report audit and tax final settlement. This resonance of technology-driven, policy-tightening, and active compliance has led to the concentrated outbreak of legacy issues in 2026.

Is This Round of Tax Make-up One-Time or a Long-Term Trend?

Regarding whether the tax make-up is limited to this year or will become a normal occurrence, the lawyer believes that the wave of huge tax make-up payments is not limited to 2026 alone, but has two layers of logic: The large-scale tax make-up in 2026 is mainly a one-time centralized clearance of historical inventory issues spanning several years (usually 3-5 years retroactively). As proactive self-inspection advances, such large retrospective tax make-ups are expected to gradually decrease in the next 1-2 years.

However, routine tax adjustments will persist over the long term. Golden Tax Phase IV's 'tax governance by data' is a permanent infrastructure; strict supervision of tax incentives (high-tech annual review, real-time review of R&D super deduction) will become the norm. Companies may still face tax make-up due to refined policy implementation and related-party transaction pricing adjustments during annual final settlement, but the amounts will return to normal levels. Tax compliance will evolve from an occasional 'mine-clearing event' to a fixed daily operating cost for enterprises.