Golden Tax Phase IV Drug Industry Tax Makeup Wave: BeiGene Subsidiary Pays 446 Million in Back Taxes

On June 26 after market close, BeiGene Ltd. (688235.SH) announced that its wholly-owned domestic subsidiary recently received a notice from the local competent tax authority. The company agreed to make certain adjustments to previously filed tax returns and has completed confirmation with the tax authority. It will promptly pay back taxes and late fees totaling approximately RMB 446 million.

The company stated that this matter does not involve administrative penalties. Based on the judgment of accounting standards for business enterprises, this matter does not constitute a prior accounting error and does not require retrospective adjustment of prior financial data. It is expected to be accounted for in current period profit or loss in 2026, with the specific impact on net profit subject to audited financial statements. The matter is not expected to have a material adverse impact on the company's financial condition, sustainable operations, or normal business.

According to BeiGene's previously released 2025 annual report, the company achieved revenue of RMB 38.225 billion in 2025, up 40.46% year-on-year; net profit attributable to parent was RMB 1.461 billion, turning from a loss of RMB 4.978 billion to profit; non-recurring net profit was RMB 1.420 billion, turning from a loss of RMB 5.379 billion to profit.

Multiple Pharmaceutical Companies Report Large Back Tax Payments This Year

Besides BeiGene, several listed pharmaceutical companies have disclosed back tax or tax adjustment announcements this year. On May 20, Aier Eye Hospital (300015.SZ) announced that after conducting a self-inspection of tax matters according to relevant laws and regulations, it confirmed the need to pay back taxes of RMB 348 million and late fees of RMB 176 million, totaling RMB 524 million.

On January 1, China Medicine (600056.SH) announced that its wholly-owned subsidiaries Sanyang Pharmaceutical and Kangli Pharmaceutical received tax notices requiring combined back tax and late fee payments of approximately RMB 65.2178 million, of which Sanyang Pharmaceutical paid back taxes of RMB 21.4862 million and late fees of RMB 10.7429 million, and Kangli Pharmaceutical paid back taxes of RMB 21.2826 million and late fees of RMB 11.7061 million.

In addition, Jiasitang (002462.SZ), Lanfan Medical (002382.SZ), and Chongyao Holdings (000950.SZ) also announced back tax payments.

Lawyer Interpretation: Golden Tax Phase IV 'Data-Driven Tax Administration' Forces Centralized Clearing of Historical Risks

Wind data shows that as of June 25, at least 80 listed companies had disclosed back tax or tax adjustment announcements this year, approaching the total of 89 for the full year 2025; the cumulative back taxes, late fees, and fines involved exceeded RMB 6 billion.

Gui Xin, a partner at Tahota (Shanghai) Law Firm and founder of Tianmu Venture Capital Ecosystem, told media that the recent back tax payments by pharmaceutical listed companies such as BeiGene and Aier Eye Hospital after the annual report are essentially a concentrated exposure of historical compliance issues in the pharmaceutical industry under Golden Tax Phase IV's strong supervision. These issues include tax incentive applicability (e.g., high-tech qualifications, R&D super deduction), tax-accounting differences, and related-party transactions, driven by high R&D investment and diverse business models.

Back tax payments often occur after the annual report because companies proactively conduct tax self-inspections after completing tax settlement and audit, a compliance choice to avoid inspection penalties. It also reflects the difference that audit focuses on financial truthfulness while tax focuses on tax law application. The lawyer pointed out that back tax payments usually belong to policy scope adjustments rather than financial fraud, representing a self-correcting 'mine clearance' in the normalization of tax compliance in the capital market.

Subsequent Impact: Huge Centralized Clearing May Fall Within 1-2 Years

Regarding whether this round of back tax payments is only for this year or will become a regular phenomenon, Gui believes there are two layers of logic: the large back tax payments clustered in 2026 are mainly a one-time centralized clearance of historical risks accumulated over many years (usually retroactive for 3-5 years). As proactive self-inspections progress, such large-scale retroactive back tax payments may gradually decrease over the next 1-2 years.

At the same time, regular tax adjustments will persist permanently. Golden Tax Phase IV's 'data-driven tax administration' is permanent infrastructure, and strict supervision of tax incentives (e.g., high-tech annual review, real-time review of R&D super deduction) will become the norm. Enterprises may still face back tax payments due to policy scope refinement and related-party transaction pricing adjustments during annual tax settlement, but amounts will return to routine levels, and concentrated 'sky-high old accounts' clearing will no longer occur. Tax compliance will solidify from an occasional event into a regular rigid operating cost for enterprises.