Business Internet China » business china » representative office annual audits
Dec 12
Representative Office annual audits
Reproduced with kind permission of China Briefing magazine

If you are a Representative office (RO), in China, what will the auditors will check and focus on ? The following article provides some tips on this subject.

The information below is limited to RO who are expenses-based taxpayers (the major category for ROs).


  • cash – are your bank statement and bank reconciliation correct ?

  • foreign currency issues - is the transaction rate entered correctly ?

  • fixed assets purchasing – has it been recorded into expenses ? If not, has it been approved by the tax authority ?

  • fixed asset disposal gain/loss – is it recorded into expenses ?

  • funds from the parent company - are these consistent with the parent company’s records ?

  • interest income/expenses - have they been identified in the expenses report correctly ?

  • expatriate Individual Income Tax ¨C for high level management, such as the Chief Representative, has the IIT calculation and pertinent rate been correctly assessed ?

  • audit fees - have the audit fees been accrued and separately entered ? Are they listed in the expenses report ?

  • rental expenses - have the rental expenses been accrued and separately entered ? Are they listed in the expenses report ?

  • employer contributions to overseas social security plans - If employees are involved in overseas social security plans, has this payment has been included into the expenses report ?

  • expenses paid on behalf of the head office - the local tax bureau may require such expenses to be recorded into the expenses report.

  • BT and FEIT payments - these tax payments should be excluded from expenses report.

  • stamp duty - is the RO subject to stamp duty ?

  • unofficial Invoices (fapiao) - has the RO received unofficial invoices (non VAT) as part of its expenses ? If so this can be subject to tax penalties.

  • business licenses and related administrative matters - the annual renewal of all of your licenses such as registration certificate, tax licenses and so on (see also separate article in this issue)

  • local employees registered with FESCO and valid work permits for expatriate staff - has all this been completed in accordance with the pertinent regulations ?


Next : Annual licensing & renewals in China

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