Expert Insights

Now! China September 2025 - Protecting Your Business: The Role of Independent Financial Investigations

Written by SBASF | Dec 5, 2025 2:39:20 AM

In today’s complex global financial landscape, where billions of dollars cross borders every day, transparency and accountability are more critical than ever. Independent financial investigations act as a safeguard against misconduct, ensuring that financial practices remain ethical, legal and fair.

Conducted by third parties such as forensic accountants, regulators or specialised firms, these investigations probe financial records to uncover irregularities, fraud or corruption. They play a pivotal role in exposing hidden financial schemes that could undermine business integrity and economic stability.

A core function is fraud detection, but the scope goes further. Investigations also support asset recovery, tracing funds through complex webs of shell companies and offshore accounts in cases of money laundering or illicit transfers. Moreover, they reinforce regulatory enforcement by strengthening compliance and governance standards.

The standard investigation process may include:

  • Direct interviews with suspects;
  • Interviews with colleagues or related parties;
  • Observation of suspect behaviours;
  • Transaction and system walkthroughs;
  • Third-party confirmations and physical asset verification

Forensic accountants play a crucial role in these investigations, analysing fraudulent activities and quantifying financial losses and damages.

Case 1-Expert Witness Report in Legal Disputes

A foreign shareholder suspected that local management manipulated revenue and understated costs during specific accounting periods to inflate the company’s profit, thereby increasing management incentives tied to KPIs. SBA was engaged to investigate. Working with external law firms, we prepared an expert witness report, which was later used in a potential legal dispute against the management team.

Case 2- Related Party Transaction Investigation

An SGX-listed group, with operations primarily in China, was queried by SGX over disclosures of asset purchases and sales between related parties within the group. The audit committee engaged RSM Stone Forest to carry out an independent financial investigation of these related party transaction. SBA supported by researching related-party relationships within and outside the group, observing physical asset transfers, reviewing cash flow records and analysing supporting agreements.

Case 3-Whistleblowing on inventory Disposal

A foreign-invested battery manufacturer received a whistleblower complaint about an unusually high waste rate in the production line. SBA was engaged to conduct an independent investigation of the production cycle, waste processing procedures and disposal methods. We identified key control weaknesses and proposed remedial actions for the company. 

 

China Updates

Accounting and Taxation

State Administration of Taxation (SAT) Announcement on VAT End-of-Period Uncredited Input Tax Refunds

General VAT taxpayers meeting the conditions for end-of-period VAT credit refund under Announcement No. 7 shall apply for refunds during the VAT filing period of the following month, after completing the current period tax filings. Applications must be submitted via the electronic tax bureau or the tax service hall.

Connection with Special Businesses (Exemption, Offset and Refund for Export, etc.):

  • Filing Compatibility: Applications for exemption, offset and refund, together with applications for end-of-period credit refunds, can be done within the same filing period.
  • Filing Obligation: Exemption, offset and refund filing shall be made on schedule. If the export sales amount eligible for exemption, offset and refund filing in the current period is zero, a zero filing for exemption, offset and refund shall be handled.
  • Processing Order: Tax authorities shall first handle exemption, offset and refund; if the taxpayer still meet the conditions afterwards, the end-of-period credit refund will then be processed.

Processing Rules of Tax Authorities:

  • General Review Time Limit: Tax authorities shall complete the review and issue a Tax Matters Notice within 10 working days from the date of accepting the application (or, if exemption/offset/refund filings must first be processed, within working days of approval of those amounts).
  • Suspension of Processing : Applications may be suspended if:
  • There are concerns about VAT-related tax risks;
  • The taxpayer is under tax inspection and the case has not been closed;
  • Abnormal VAT filings have not been resolved;
  • Abnormal VAT deduction certificates have not been addressed;
  • Other circumstances as stipulated by the State Taxation Administration.

If the taxpayer remains eligible once these matters are resolved, the authority shall complete the review and approve the refund within 5 working days. If not eligible, a notice of refusal must be issued within 5 working days.

Terminating of Processing: Applications will be terminated if major tax violations are suspected such as fraudulent export tax refund or false issuing of VAT special invoices. A notice shall be issued within 5 working days. Taxpayers may reapply once the issues are addressed.

This Announcement takes effect from 1 September 2025.

 

MOF and STA Announcement on the Value Added Tax (VAT) policy for interest income on treasury and other bonds

This announcement clarifies the VAT treatment of interest income earned on national government bonds, local government bonds and financial bonds.

Effective Date and Transitional Rules

  • From August 8, 2025, interest income from newly issued national government bonds, local government bonds, and financial bonds shall be subject to VAT.
  • Interest income from bonds issued before this date remains exempt from VAT until maturity, including subsequent tranches issued under the original terms of such pre-existing bonds.

Definition of Financial Bonds

For this announcement, the term "financial bonds" refer to negotiable securities that:

  • Are issued by financial institutions legally established within the territory of the People's Republic of China;
  • Are Issued in the national interbank and/or exchange bond markets;
  • Carry obligations to pay interest and repay principal under agreed terms; and
  • Are held by financial institutions.

 

Human Resources

Notice on Printing and Distributing the Application Guidelines for the Fiscal Subsidies for Overseas Talents under the Personal Income Tax Preferential Policies of the Guangdong-Hong Kong-Macao Greater Bay Area in Guangzhou City for the 2023 and 2024 Tax Years (2025)

On August 19, 2025, the Finance Bureau of Guangzhou City, together with the Taxation Bureau of Guangzhou City and other government departments issued the "Notice on Printing and Distributing the Application Guidelines for the Fiscal Subsidies for Overseas Talents under the Personal Income Tax Preferential Policies of the Guangdong-Hong Kong-Macao Greater Bay Area in Guangzhou City for the 2023 and 2024 Tax Years (2025)".

The guidelines provide that overseas talents, including high-end and scarce talents, working within the administrative region of Guangzhou who meet the eligibility conditions may apply for fiscal subsidies. The subsidy applies to the portion of personal income tax paid in Guangzhou for the 2023 and 2024 tax years (1 January to 31 December) that exceeds 15% of taxable income.

  • This subsidy is exempt from individual income tax.
  • The maximum fiscal subsidy for each taxpayer is CNY 5 million per tax year.

 

Corporate Governance

The Supreme People's Court issues first batch of typical cases on foreign-related commercial and maritime mediation

On 11 July 2025, the Supreme People's Court released the first batch of six typical cases involving foreign-related commercial and maritime mediation. These cases involved parties from  Singapore, South Korea, Italy, and the United States, and showcase China’s growing experience in diversified dispute resolution for cross-border matters. 

The case emphasize equal protection of the legitimate rights and interests of both Chinese and foreign parties. Innovative approaches adopted by the courts include:

  • Coordination between two court levels;
  • Circuit trials;
  • A "one mediation for multiple cases" strategy
  • Phased performance plans;
  • A dual mediation model combining "technology + law";
  • Use of third-party mediation.

These practices aim to strengthen cross-border trade dispute resolution, safeguard the interests of foreign investors and establish new paradigms for international commercial mediation.