Case analysis reveals reliance on negotiation and administrative channels among foreign taxpayers in China, suggesting litigation remains a rare mechanism for resolving cross-border tax disputes.
This article examines how foreign taxpayers resolve cross-border tax disputes in China, focusing on litigation, administrative reconsideration and negotiation. Using the S Company case and recent reforms, it argues that litigation remains exceptional, while preventive strategies and alternative mechanisms are central to managing tax uncertainty.
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Dongmei Qiu (2026) studied this question.
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