Pharma back-tax wave: Golden Tax Phase IV forces compliance cleanup

On June 26 after market close, BeiGene (688235.SH) announced that its domestic wholly-owned subsidiary recently received a notice from the local competent tax authority, and the company agreed to certain adjustments to previously filed tax returns. The company has confirmed with the tax authority and will pay back taxes and late fees totaling approximately 446 million yuan. That figure is about 30% of the company's 2025 net profit.

According to BeiGene's previously disclosed 2025 annual report, the company realized revenue of 38.225 billion yuan in 2025, up 40.46% YoY; net profit attributable to parent was 1.461 billion yuan, turning from a loss of 4.978 billion yuan; recurring net profit was 1.420 billion yuan, turning from a loss of 5.379 billion yuan.

BeiGene stated that it recently received a notice from the local tax authority regarding tax matters, making several adjustments to previously filed tax returns. The company communicated with the authority on technical determination and tax-accounting differences, and will complete the payment. This matter does not involve administrative penalties. Based on accounting standards, the matter is not a prior period accounting error and does not require retrospective adjustment of prior period financial data.

The company expects this matter to be recorded in 2026 current profit or loss; the specific impact is subject to audited financial statements, and is not expected to materially adversely affect financial condition, going concern, or normal operations.

Multiple pharma companies this year have huge back-tax or tax adjustments

Besides BeiGene, several other pharma companies have disclosed back-tax announcements this year.

On May 20 morning, AIER Eye Hospital (300015.SZ) announced that after self-checking tax matters, it confirmed the need to pay back taxes of 348 million yuan and late fees of 176 million yuan, totaling 524 million yuan.

On January 1, China Pharma (600056.SH) announced that its wholly-owned subsidiaries Sanyang Pharma and Kangli Pharma received tax notices, requiring back taxes and late fees totaling about 65.22 million yuan, including Sanyang 21.49 million yuan back tax and 10.74 million yuan late fee; Kangli 21.28 million yuan back tax and 11.71 million yuan late fee.

Additionally, companies like JiaShiTang (002462.SZ), BlueSail Medical (002382.SZ), and Chongqing Pharma (000950.SZ) also issued back-tax announcements.

Lawyer interpretation: Golden Tax Phase IV's strengthened oversight drives centralized settlement of historical issues

According to incomplete Wind data, as of June 25, at least 80 listed companies have disclosed back-tax or tax adjustment announcements this year, approaching the full-year 2025 total of 89, involving over 6 billion yuan in back taxes, late fees, and penalties.

Gui Xin, senior partner at Tahota Law Firm and founder of Tianmu Venture Ecosystem, said that recent back-tax incidents by BeiGene, AIER, etc., after annual reports, essentially reflect the concentrated exposure of historical compliance issues under Golden Tax Phase IV's strong supervision, including tax incentive applicability (e.g., high-tech qualification, R&D super deduction), tax-accounting differences, and related-party transactions in the pharma industry with high R&D investment and diverse business models. Back-taxes often occur after annual reports, partly reflecting companies' voluntary tax self-checks after completing annual settlement and audit to avoid inspection penalties, and also highlighting the difference between audit focusing on financial authenticity and tax focusing on compliance. The lawyer believes back-tax usually stems from policy caliber adjustments, not financial fraud, representing a normal "mine-clearing" self-correction in capital market tax compliance.

The lawyer further pointed out that the frequent occurrence of huge back-taxes in pharma and other industries this year, far exceeding previous years, is mainly due to the full implementation of Golden Tax Phase IV achieving multi-department data penetration, coupled with stricter supervision of tax incentives and the implementation of the VAT Law, forcing companies to centrally settle historical tax issues from the past five or even ten years. Meanwhile, listed companies, considering avoiding high penalties and information disclosure risks, choose to voluntarily "clear mines" after annual audit and settlement, causing previously hidden stock issues to erupt centrally in 2026, forming a concentrated back-tax phenomenon.

Will this back-tax wave become long-term? Amounts may gradually return to normal

Regarding whether this back-tax wave is limited to this year or will have long-term effects, the lawyer believes huge back-taxes are not limited to 2026. The logic has two layers: the concentrated large back-taxes in 2026 mainly involve a one-time settlement of historical stock issues over several years (typically 3-5 years lookback); as proactive self-checks advance, such huge retroactive back-taxes may gradually decrease in the next 1-2 years. However, routine tax adjustments will persist long-term. Golden Tax Phase IV's "data-driven tax administration" is a long-term infrastructure; strict supervision of tax incentives (high-tech annual review, real-time R&D super deduction review) will become normal. Future annual settlements may still generate back-taxes due to policy caliber details or related-party pricing adjustments, but amounts will return to normal levels, without concentrated "sky-high old account" settlements. Tax compliance will solidify from occasional "mine-clearing events" into a routine rigid operating cost for companies.