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Financial & Tax Policies Hainan Free Trade Port Tax-Related Professional Services Regulations

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Tropical Hainan
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Editor’s note: This document is a local regulation (地方性法规) formally titled:

《海南自由贸易港涉税专业服务规定》Hainan Free Trade Port Tax-Related Professional Services Regulations

It was adopted by the Standing Committee of the Seventh Hainan Provincial People’s Congress on September 30, 2025, and comes into force on November 1, 2025.
That means it is binding law within Hainan Province, not merely a guideline or departmental notice.

What it regulates

It standardizes how tax-related professional services (涉税专业服务) are provided within the Hainan Free Trade Port.

That covers:

Who can legally offer such services – Certified Tax Agents (税务师), accounting and law firms, etc.

What kinds of services – tax consulting, compliance planning, attestation, representation, and reporting.

Professional rights and duties – confidentiality, independence, objectivity, accuracy.

Credit and supervision systems – real-name registration, credit scoring, and public rating for institutions and individuals.

Penalties – administrative fines, credit downgrades, and disqualification for misconduct.

(A) Regulations text

Hainan Free Trade Port Tax-Related Professional Services Regulations
(Adopted at the 20th Meeting of the Standing Committee of the Seventh Hainan Provincial People’s Congress on 30 September 2025)

Article 1

To regulate tax-related professional service activities, promote the standardized, orderly, and healthy development of the tax-related professional services industry, safeguard national tax revenue interests, protect the lawful rights and interests of taxpayers, and foster a market-oriented, law-based, and internationalized business environment, these Regulations are formulated pursuant to the Hainan Free Trade Port Law of the People’s Republic of China, the Law of the People’s Republic of China on the Administration of Tax Collection, and other relevant laws and regulations, in light of the actual circumstances of the Hainan Free Trade Port.

Article 2

These Regulations apply where tax-related professional service institutions and tax service personnel provide tax-related professional services within the Hainan Free Trade Port.

“Tax-related professional services” means services such as tax agency, tax consulting, and tax-related attestation, provided to clients regarding tax-related matters upon entrustment and by using professional knowledge and skills.

“Tax-related professional service institutions” include CTA firms (税务师事务所) and accounting firms, law firms, bookkeeping agencies, tax agency companies, finance-and-tax consulting companies, professional or customs-brokerage enterprises, and other institutions that provide tax-related professional services.

“Tax service personnel” means persons employed by or engaged through tax-related professional service institutions to provide tax-related professional services, as well as other persons who provide such services under laws, regulations, or rules.

Article 3

Tax-related professional service institutions and tax service personnel shall, in providing services, adhere to the principles of independence, objectivity, impartiality, and compliance; observe laws, regulations, and relevant provisions; exercise due diligence; abide by professional ethics; and follow business norms for tax-related professional services.

Tax-related professional services lawfully carried out by institutions and personnel are protected by law.

Article 4

Entities and individuals may voluntarily entrust tax-related professional service institutions and tax service personnel to provide tax-related professional services.

Entities and individuals are encouraged to engage institutions and personnel with strong professional capabilities and higher credit ratings or credit points.

Article 5

Tax-related professional services include:

(1) Acting as agent for tax declarations;
(2) General tax consulting;
(3) Professional (retained) tax advisory;
(4) Tax compliance planning;
(5) Tax-related attestation (鉴证);
(6) Examination of tax-payment status;
(7) Other tax-related professional services.

Items (1), (2), and (7) are general tax-related professional services. Items (3) through (6) are specific tax-related professional services.

Specific tax-related professional services shall be undertaken by CTA firms, or by accounting firms or law firms that provide tax-related professional services; relevant documents shall be signed by a Certified Tax Agent (CTA), Certified Public Accountant (CPA), or lawyer, who shall bear corresponding responsibility.

Article 6

Tax-related professional service institutions and personnel are encouraged to provide the following services in the Hainan Free Trade Port:

(1) Specialized consulting on Hainan FTP tax policies, international tax policies, etc.;
(2) Cross-border tax-related professional services, including tax services for cross-border individuals and tax services facilitating cross-border investment and financing;
(3) Services relating to the alignment between the FTP tax system and tax systems in other domestic regions;
(4) Services such as tax risk management and tax compliance reviews (审核);
(5) Assisting relevant government departments with tax and economic analysis, investigation, and evaluation, including enterprise credit information inquiries, business-environment evaluations, and high-quality economic development surveys;
(6) Building intelligent (digital) tax-related professional service platforms and using modern information technology to provide such services;
(7) Other tax-related professional services encouraged by the State and the Hainan FTP.

Article 7

Foreign (overseas) individuals are encouraged, in accordance with State and Hainan FTP provisions, to sit the CTA qualification examination and to provide tax-related professional services in the Hainan FTP.

Overseas tax-related professional service institutions are encouraged, in accordance with State and Hainan FTP provisions, to participate in tax-related professional services in the Hainan FTP.

Article 8

When providing tax-related professional services, institutions and personnel enjoy the following rights:

(1) To consult, in accordance with law, tax laws, regulations, rules, and administrative normative documents with the tax authorities and with Customs;
(2) To request that clients provide relevant tax-related materials and the necessary working conditions or other assistance;
(3) Upon acceptance of an engagement, and with a power of attorney and identification documents, to consult the client’s tax-related materials at the tax authorities and Customs and to communicate on tax-related matters;
(4) Other rights provided by laws and regulations.

Article 9

When providing services, institutions and personnel shall:

(1) Act in good faith and conduct business independently, objectively, and impartially in accordance with law;
(2) Where they discover client conduct that is illegal or non-compliant and may affect the fairness or integrity of the service outcome, dissuade the client; where dissuasion fails, promptly suspend the service;
(3) Where performing tax-related attestation or examination of tax-payment status, recuse themselves if there exist interest relationships with the client, the attested party, the party under review, or other relevant parties that affect independence;
(4) Be responsible for the authenticity and legality of the tax-related reports and documents they issue;
(5) Keep confidential, pursuant to law and contract, State secrets, trade secrets, personal privacy and personal information, and tax-related information learned in the course of providing services;
(6) Perform any other obligations provided by laws and regulations.

Tax service personnel shall maintain professional competence by continuously acquiring and updating knowledge and skills in laws and regulations, tax practice, and information technology through continuing education and professional training.

Article 10

Institutions and personnel shall enter into a business engagement agreement with the client, specifying the service scope, method, term, fees, form and intended use of deliverables, rights and obligations, liability for breach, dispute resolution, and other necessary matters.

Clients bear responsibility for the authenticity, completeness, and legality of the tax-related materials they provide.

Article 11

Institutions shall, in line with business norms for tax-related professional services, improve internal controls, establish quality-management systems and risk-control mechanisms, and standardize business acceptance and performance.

Institutions shall establish business record-keeping to document the practice process. Where tax-related reports and documents are to be issued, they shall be signed by the handling tax service personnel and stamped with the institution’s seal before delivery to the client; both parties shall retain copies for future reference.

Article 12

Institutions and personnel shall not:

(1) Employ or designate personnel who do not meet State requirements to perform specific tax-related professional services;
(2) Permit other institutions or personnel to conduct business in the name of their own institution or person, or conduct business in the name of other institutions or personnel without authorization;
(3) In violation of tax laws and regulations, illegally provide bank accounts, tax-related certificates, invoices, etc. to clients, resulting in unpaid or underpaid taxes, or fraudulently obtaining tax preferences;
(4) In violation of tax laws and regulations, during the provision of services, fail to handle tax declarations or withhold/remit taxes within statutory time limits, with required content, and as required, or misapply tax rates or preferential policies when calculating tax payable, resulting in unpaid or underpaid taxes;
(5) Depart from professional service norms and issue false opinions;
(6) Use improper competition methods—such as concealment, fraud, bribery, collusion, kickbacks, improper promises, malicious low pricing, false tax-related publicity, illegal tax-related advertising, or disparaging/defaming other institutions or personnel—to secure business, thereby harming national tax revenue interests or the interests of clients or others;
(7) Publicly distort or misinterpret State or Hainan FTP tax policies and disrupt the normal tax order;
(8) Use insider information, non-public information, trade secrets, personal privacy and personal information, or tax-related information obtained by virtue of service to seek improper benefits;
(9) Provide improper benefits to tax authority or Customs staff, their spouses, children and their spouses, other relatives, or other specified related persons, or instruct/induce clients to provide improper benefits;
(10) Engage in any other conduct in violation of laws, regulations, or rules.

Article 13

The Tax Agents (CTA) Industry Association is the self-regulatory organization for tax-related professional service institutions and personnel, including CTA firms and CTAs. It implements self-regulatory management pursuant to laws, regulations, rules, and its articles, and is subject to the supervision and guidance of the tax authorities. The Association shall strengthen industry self-discipline and integrity, and give full play to the exemplary and leading role of CTAs and other professionals.

Institutions and personnel are encouraged to join the Association on a voluntary basis, equally enjoy the rights provided by its articles, and fulfill the corresponding obligations.

Industry associations are encouraged to build internationalized, digital platforms; promote alignment with international rules in the field of tax-related professional services in the Hainan FTP; strengthen professional talent development; and advance international exchanges and cooperation.

Article 14

Tax authorities shall accord necessary good-faith recognition and professional reliance to tax-related reports and documents—such as business reports, professional opinions, and tax forms—issued by institutions and personnel.

Tax-related attestation reports lawfully issued by CTAs, CPAs, or lawyers have evidentiary effect.

Article 15

Tax authorities shall strengthen the management and services for institutions and personnel, establishing and improving real-name-based credit-management and risk-management mechanisms for tax-related professional services.

Institutions and personnel shall lawfully obtain a credit code and provide services under their true identity.

Article 16

Tax authorities shall evaluate the credit status of institutions by combining credit points with credit ratings.

For personnel, tax authorities shall combine credit points with practice negative records, establish a cumulative credit-points incentive mechanism, and provide access for individuals to query and download their own credit records.

Through the portal website, the e-tax bureau, tax service halls, and other channels, tax authorities shall publicize: institutions under real-name management and their credit status; institutions/personnel with high credit ratings or points; and institutions/personnel listed as discredited (untrustworthy) tax-service subjects.

Article 17

For institutions with higher credit ratings, tax authorities shall, via information platforms, provide facilitation such as batch tax declarations and bulk information submissions, and offer dedicated zones, dedicated windows, and dedicated personnel to institutions with higher credit ratings and personnel with higher credit points.

Tax authorities shall, through online and offline means, provide publicity, training, and guidance concerning tax policies, tax-handling procedures, and management systems to institutions and personnel.

Tax authorities shall establish and improve a tripartite communication mechanism among the tax authorities, institutions/personnel and their industry associations, and taxpayers, to regularly solicit opinions and suggestions, analyze and resolve issues, and provide feedback.

Tax authorities may engage, in a targeted manner, in cooperation with institutions regarding tax compliance.

Article 18

For violations of Article 12(1)–(2), the competent tax authority at the location of the institution/personnel shall issue prompts/reminders, deduct credit points, or include the matter in a negative credit record; where circumstances are relatively serious or corrections are not made within the time limit, it shall designate the party as a key supervision target, deduct credit points, downgrade the credit rating, or include the matter in a negative credit record, and issue risk alerts to the client and to the client’s competent tax authority; where circumstances are serious, it shall list the party as a discredited (untrustworthy) tax-service subject and make a public announcement, issue risk alerts as above, and require that any tax-related business handled by the party be conducted on-site at the tax authority jointly by the party and the client.

Where institutions or personnel commit tax-related illegal or non-compliant conduct and are dealt with by the Cyberspace Administration, market regulation, finance, supervisory authorities, or industry self-regulatory organizations in accordance with relevant provisions, the competent tax authority at their location may, based on actual circumstances, deduct credit points, downgrade the credit rating, include the matter in a negative record, or designate them as a key supervision target or a discredited tax-service subject.

Article 19

For violations of Article 12(1)–(2), the tax authority shall issue a warning, order corrections within a time limit, confiscate illegal gains, and impose fines as follows: on institutions RMB 5,000–10,000, on individuals RMB 1,000–5,000; where circumstances are relatively serious or corrections are not made within the time limit: on institutions RMB 10,000–30,000, on individuals RMB 5,000–10,000; where circumstances are serious: on institutions RMB 30,000–50,000, on individuals RMB 10,000–30,000. Where a crime is constituted, criminal liability shall be pursued according to law.

Article 20

When investigating tax-violation cases, if tax authorities discover that institutions or personnel providing tax-related professional services are suspected of tax evasion, false invoicing, or assisting taxpayers in tax evasion or false invoicing, they shall investigate and handle such conduct concurrently.

Article 21

Customs shall, in accordance with relevant State provisions, supervise and serve the institutions and personnel that provide services relating to tariffs and taxes collected by Customs as collecting agent.

Article 22

Where these Regulations set no penalties for particular conduct, but other laws, regulations, or rules do, those provisions shall apply.

Article 23

These Regulations shall take effect on 1 November 2025.

(B) Interpretation — What the Regulations Actually Say

The Hainan Free Trade Port Tax-Related Professional Services Regulations were adopted by the Standing Committee of the Seventh Hainan Provincial People’s Congress on September 30 2025 and take effect November 1 2025.
They are the first local law in China to clearly define who may provide tax-related professional services, what standards they must meet, and how they will be supervised and penalized within the Hainan Free Trade Port.

1. Purpose

The Regulations give legal force to the professional management of Hainan’s tax advisory industry.
They aim to:

  • Support the FTP’s zero-tariff, low-tax-rate, simplified-system reforms;

  • Ensure fair, transparent, and compliant tax-related services;

  • Strengthen trust between taxpayers, service providers, and the tax authorities.

2. Scope

Applies to all institutions and individuals offering tax-related professional services in the FTP — including Certified Tax Agent (CTA) firms, accounting and law firms, bookkeeping agencies, tax and finance consultancies, and customs-brokerage enterprises.

3. Main Provisions

Area Key Points
Permitted services Seven categories, from general consulting and declaration to specialized advisory, compliance planning, attestation, and tax-payment reviews.
Qualifications Only licensed CTAs, CPAs, or lawyers may sign and take responsibility for “specific” services.
Rights Service providers may consult tax laws and obtain client tax information with proper authorization.
Obligations Must act independently and objectively, maintain confidentiality, and ensure reports are true and lawful.
Prohibitions No false reporting, misuse of tax incentives, bribery, collusion, or public misinterpretation of FTP tax policy.
Credit system Real-name registration, credit codes, points, and public ratings for both institutions and individuals.
Incentives High-credit firms receive faster processing, dedicated service windows, and online facilitation.
Penalties Warnings, fines, credit downgrades, loss of qualification, and—if criminal—prosecution.

4. Oversight Structure

Tax authorities manage registration, credit scoring, and supervision.

The CTA Industry Association enforces professional self-discipline and ethics.

Customs supervises services connected with tariffs and taxes it collects.

Joint mechanisms allow information-sharing and “professional reliance,” meaning tax authorities can trust and reference certified reports.

5. International Relevance

The Regulations open the sector to foreign institutions and professionals who meet FTP and national requirements, aligning Hainan’s tax-service framework with international standards.


In short:
This is not a guideline but binding provincial law.
It formalizes who can provide tax services in the Hainan FTP, sets professional and ethical standards, introduces a credit-based supervision system, and enforces penalties for violations—laying the foundation for a modern, internationally aligned tax-service environment.

This topic was modified 10 hours ago 3 times by Tropical Hainan
This topic was modified 10 hours ago by Patrick Quinn
This topic was modified 9 hours ago by Patrick Quinn

   
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