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Chinese offshore investment
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China intensifies cross-border tax scrutiny as Beijing warns against offshore dodging

Major financial outlets blast offshore shell structures after case involving the Hong Kong entity of a mainland social media platform

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A mobile screen shows the Momo dating app, operated by Hello Group, which was required to pay hundreds of millions of yuan in back taxes this year. Photo: Simon Song
Themis Qi

Two Chinese state media outlets warned on Monday against offshore tax evasion by calling out an incident involving a major social media platform and its Hong Kong entity, sending a message that Beijing is intensifying its scrutiny of cross-border corporate structures.

The China Securities Journal, which is affiliated with Xinhua, and the Financial News, which is supervised by China’s central bank, revealed the enforcement action, highlighting a broader regulatory tightening over the way mainland firms use offshore hubs to manage money.

The Hong Kong entity in question was denied “beneficial owner” status by tax authorities because it failed to meet the criteria for substantive business operations, according to the Financial News report.

Consequently, the entity failed to qualify for the preferential 5 per cent tax rate under the Mainland and Hong Kong Closer Economic Partnership Arrangement (CEPA), meaning it was subject to a 10 per cent mainland rate.

“Cross-border tax planning structures based merely on ‘formal compliance’ are no longer viable; structural designs must align with genuine commercial substance,” the Financial News reported.

The social media platform was said to have paid an additional 356.1 million yuan (US$52.6 million) in taxes on distributed dividends and accrued an extra 191.8 million yuan in withholding tax for undistributed dividends.

Neither state media report identified the company by name.

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