Anhui Tax Bureau Publishes 2026 CIT Filing Guidelines: 7 Changes Foreign Investors Must Know

The Anhui Provincial Tax Service of the State Taxation Administration (国家税务总局安徽省税务局, guójiā shuìwù zǒngjú ānhuī shěng shuìwù jú) released its 2026 Corporate Income Tax (企业所得税, qǐyè suǒdé shuì) annual filing guidelines on February 3, 2026, introducing 7 mandatory data fields and 3 new annexes that directly impact foreign-invested enterprises (外商独资企业, WFOE, wàishāng dúzī qǐyè) across the province. The new requirements take effect for the tax year 2025 filing season, with the statutory deadline set for May 31, 2026. Anhui is the eighth provincial-level tax authority to issue updated guidance under the State Taxation Administration’s broader digital tax reform, making it a critical reference point for the 15,000+ WFOEs currently registered in the province.

What Changed in the 2026 CIT Filing Form

The 2026 guidelines revise Schedule A105050 — the core annex for wage and expense deductions — by adding 7 mandatory data fields that require itemized breakdowns of salary, welfare, and training costs by employee nationality and contract type. This replaces the previous aggregate reporting method and is designed to give Anhui tax auditors granular visibility into how foreign-invested enterprises structure their compensation packages. According to the Anhui Tax Service, pilot data from 2025 showed that 12% of sampled WFOEs in Hefei and Wuhu had misreported cross-border payroll allocations, prompting the expanded disclosure requirements.

In addition to Schedule A105050, the guidelines introduce 3 new annexes specifically for related-party transaction reporting. These annexes require WFOEs to disclose: (a) all intra-group service agreements with overseas parent companies, (b) royalty and licensing fee schedules for intellectual property used in Anhui operations, and (c) financing arrangements with related parties exceeding RMB 10 million. The third annex is particularly significant because it applies a new materiality threshold — previously set at RMB 50 million for Anhui filers — meaning hundreds of mid-sized WFOEs will now be captured by transfer pricing documentation rules for the first time.

The digital submission system, accessed via the 电子税务局 (e-Tax Bureau, diànzǐ shuìwù jú) portal, has also been upgraded to pre-flag incomplete filings. During a January 2026 beta test covering 500 enterprises in the Hefei High-Tech Zone, the system rejected 34% of initial submissions due to missing fields or format errors, compared to a 12% rejection rate in the 2025 cycle. This sharp increase reflects the higher data granularity now required and signals that foreign investors should expect more rigorous automated validation before their filings are accepted.

Anhui-Specific Implementation and Processing Timelines

While the State Taxation Administration issued national-level CIT filing templates in late 2025, Anhui has chosen to implement a stricter submission window than some neighboring provinces. Foreign-invested enterprises filing in Anhui must submit their complete annual return package — including all new annexes — by May 15, 2026, rather than the statutory May 31 deadline, if they wish to qualify for priority processing of any refund claims. The Anhui Tax Service has stated that refund requests attached to filings submitted between May 16 and May 31 will be processed within 45 working days, while those submitted by May 15 will be processed within 20 working days — a 25-day reduction that represents up to a 55% faster turnaround.

This incentive structure is part of Anhui’s broader effort to streamline tax administration for foreign investors. In 2025, the province processed an average of 2,300 CIT refund applications from WFOEs, with a total refund value of approximately RMB 1.8 billion. Under the previous timeline, 38% of these refunds took longer than 60 working days to settle. Based on the new guidelines, the Anhui Tax Service projects that 85% of early-submission refunds will be completed within 30 working days, offering meaningful working capital relief for WFOEs that meet the May 15 cutoff.

Another Anhui-specific feature is the requirement for all related-party transaction annexes to be submitted in both Chinese and English for the first time. Previously, English-only submissions were accepted for WFOEs with majority foreign ownership. The 2026 guidelines mandate that every field and supporting note must include a Chinese-language equivalent, validated by a certified translator registered with the Anhui Justice Department. The estimated cost per filing is RMB 3,000 to RMB 8,000 for translation and notarization services, depending on the complexity of the transaction structure.

Penalties for Late or Incorrect Filing Under the 2026 Guidelines

The enforcement framework has not changed in terms of penalty rates, but the increased data requirements mean that the risk of triggering penalties is substantially higher for foreign investors who file without comprehensive internal preparation. Late filing penalties remain at 0.05% of the tax payable per day, capped at 40% of the total tax due. Underpayment penalties, where discrepancies are identified during audit, range from 50% to 200% of the underpaid amount, with a 100% penalty floor if the error is deemed to involve related-party transaction manipulation. In 2025, the Anhui provincial tax authority conducted 214 CIT audits on WFOEs and assessed a cumulative RMB 47 million in underpayment penalties, with an average penalty of RMB 220,000 per case.

The 2026 guidelines also introduce a new pre-filing compliance review option for WFOEs with annual revenue exceeding RMB 50 million. This optional review allows enterprises to submit draft filings for auditor feedback before the formal deadline, reducing the risk of post-filing audits. The Anhui Tax Service has allocated 40 dedicated compliance officers across Hefei, Wuhu, Ma’anshan, and Bengbu to handle these reviews, with an estimated processing time of 10 business days per submitted draft. However, only 120 slots have been made available for the 2026 filing season across the entire province, meaning demand is likely to outstrip supply — foreign investors should apply for this service no later than March 15, 2026, to secure a slot.

One additional enforcement change worth noting: the 2026 guidelines explicitly state that WFOEs with incomplete or missing annexes at the time of submission will not receive extension approvals. In previous years, Anhui tax authorities routinely granted 30-day extensions to WFOEs that needed additional time to compile related-party documentation. The new policy eliminates this flexibility, making May 31 a hard deadline with no blanket extension pathway. Enterprises anticipating documentation delays should begin internal data collection immediately and consider engaging third-party tax advisors to pre-audit their filing packages.

Recommended Steps for Foreign Investors Filing in Anhui

Based on the scale of changes introduced in the 2026 guidelines, foreign-invested enterprises operating in Anhui should begin preparing their CIT filing packages immediately. Enterprises that wait until April 2026 — when peak filing volume typically begins — will face significant pressure to meet the May 15 early-submission deadline for fast-tracked refund processing. Given that the system pre-validation rejection rate has nearly tripled to 34%, a single resubmission cycle could consume 7-10 working days, making April starts risky for WFOEs that want priority refund treatment.

For WFOEs that have not yet conducted a transfer pricing review of their related-party transactions, the new RMB 10 million materiality threshold means that standard intercompany service agreements — such as management fee allocations, software licensing, or technical support arrangements — may now require formal documentation that did not apply in prior years. A targeted transfer pricing health check, focused on the three new annex categories, should be completed no later than April 15, 2026, to allow sufficient time for any corrective adjustments before filing.

Foreign investors should also verify that their internal payroll and HR systems can produce the new itemized breakdowns required for Schedule A105050. Specifically, compensation data must now be segmented by nationality (Chinese vs. foreign employees), contract type (direct hire vs. secondment), and cost center location within Anhui. Companies using legacy payroll platforms that only provide aggregate totals will need to either upgrade their systems or build manual reconciliation processes to generate the required data fields.

NEXT STEPS

1. Conduct a 2026 CIT readiness assessment — Review your current reporting structure against the 7 new Schedule A105050 fields and the 3 new related-party transaction annexes. Access our CIT Readiness Checklist for Anhui WFOEs →
2. Apply for the pre-filing compliance review — If your WFOE has annual revenue exceeding RMB 50 million, submit your draft filing application to the Anhui Tax Service office in your city by March 15, 2026. Learn how to apply for pre-filing review →
3. Audit your intercompany transaction thresholds — Identify all related-party agreements with values above RMB 10 million and begin compiling the required documentation for the three new annexes. Read our Anhui Transfer Pricing Documentation Guide →

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