

07 Part Seven International Cooperation
updated:2025-08-14 China
International cooperation refers to a series of cooperative activities among tax authorities of different jurisdictions to achieve the goals of cross-border tax administration collaboration, prevention of international tax evasion and promotion of international trade and investment.
Tax-related information is exchanged among tax authorities of various jurisdictions in accordance with applicable instruments such as tax treaty, tax information exchange agreement or multilateral convention, including the exchange of taxpayers' basic information, financial information, transaction information, etc., in order to strengthen tax administration and crack down on cross-border tax evasion. Information exchange methods include exchange of information on request, automatic exchange of information, and spontaneous exchange of information.
The competent authority of a contracting jurisdiction may raise specific questions regarding specific tax cases and request the competent authority of the other contracting jurisdiction to provide information to assist in its tax investigation and verification in accordance with applicable instrument, which includes acquisition of shares or properties, verification of transactions, materials employed by the subjects, residency status of companies or individuals, the receipt or payment of money, the transferring or use of property, etc.
The competent authorities of the contracting jurisdictions may, by agreement between them, automatically exchange tax information in batches concerning one of various categories of taxpayers' income, e.g. financial account information or country-by-country reports. Currently, the automatic exchange of financial account information for tax purposes is the predominant form of automatic exchange of information conducted internationally. This process involves financial institutions in participating countries (regions) identifying non-resident account holders and reporting relevant information to their competent tax authorities in accordance with the Common Reporting Standard (CRS). Subsequently, these competent authorities will automatically exchange the information with the relevant foreign jurisdictions.
The competent authorities of a contracting jurisdiction may provide competent authorities of the other contracting jurisdiction with information obtained in the course of tax law enforcement that is considered to be useful to the competent authorities of the other contracting jurisdiction in implementing the tax treaty and the domestic laws of the taxes covered by it. The information includes tax-related circumstances and materials in relation to the receipt or payment of money or expenses, the transfer or use of property, etc.
Tax authorities of two or more jurisdictions may jointly conduct tax audits of multinational enterprises or cross-border transactions with common concerns, depending on the tax law and regulation of the respective jurisdiction. Through jointly selecting audit targets, forming joint audit teams, jointly developing audit plans, conducting comprehensive examinations, and issuing audit reports, joint audit helps enhance audit efficiency, strengthen audit effectiveness, and safeguard the tax rights and interests of participating jurisdictions.
Governments may adopt a series of measures to prevent multinational enterprises and individuals from evading tax obligations through various means, and safeguard the taxing rights and interests of the country (region) and a fair tax order. By concluding bilateral or multilateral tax treaties, taxing rights are allocated among countries (regions), so as to avoid double taxation and prevent multinational enterprises from evading taxes by incorrect transfer pricing.
[Tax Administration Product No.15: Strengthening Cross-border Tax Collaboration and Addressing Tax Challenges Raised by Globalization] (to be released in 2029)
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