The short answer
Five filings define the year, and they are not interchangeable:
| Filing | Goes to | Deadline |
|---|---|---|
| Annual report | Market regulation (national credit system) | 30 June |
| CIT annual settlement | Tax authority | 31 May |
| FDI information report | Commerce ministry system | 30 June |
| Foreign-exchange equity registration | FX platform | 30 June |
| Audit report | Internal, then used by the filings above | Before the settlement |
Then there is the July reset of the social-insurance and housing-fund bases, which is not a filing at all but changes every payroll for the next twelve months.
The calendar, month by month
| Period | What happens |
|---|---|
| January | Prior-year books closed; audit fieldwork starts; annual report data assembled |
| February | Audit draft; CIT settlement calculations; outstanding invoices reconciled |
| March | Individual income tax annual reconciliation opens for employees (1 March); annual report filed where ready |
| April | CIT settlement filed or in review; FDI and FX registrations prepared |
| May | CIT settlement due 31 May; annual report and FDI/FX filing continue |
| June | Annual report, FDI report and FX registration all due 30 June |
| July | Social-insurance and housing-fund bases reset; payroll recalculated |
| September | Disabled-employment fund (where applicable, city-dependent) |
| October | Q3 filings; next year’s audit planning |
| December | Year-end closing, invoice reconciliation, physical stocktake where relevant |
The clustering is the problem. Four obligations land in the same six weeks, and each depends on the audit, which depends on the books being closed, which depends on the invoices being reconciled. A company that starts in May is already late.
The three reports people confuse
The annual report is the public one. It goes to the market-regulation system, is visible to anyone, and covers the company’s status, shareholders, capital contributed and a summary of operations. Being late puts the company on the abnormal-operation list.
The FDI information report goes to the commerce ministry’s system and is about the foreign investment itself: the investor, the capital contributed, the manner of investment, the business and the employees. It is not public in the same way and it is not the tax filing.
The foreign-exchange registration goes to the FX platform and reconciles the capital account: what was contributed, what was remitted, what the equity position is at year end. A company that contributed capital but never registered it will find the remittance of profits or the repatriation at exit blocked.
The tax settlement is separate again: it reconciles accounting profit to taxable profit, applies the adjustments, and settles the year’s corporate income tax.
The audit is the input, not the output
For a foreign-invested company the audit is not a formality that follows the filings; it is the document the filings are built from. The auditor needs the bank statements, the contracts, the invoices, the payroll and the related-party transactions, and the report has to be ready before the tax settlement is filed.
Two audit issues recur. Related-party pricing — management fees, service fees, royalties paid to the overseas parent — has to be supportable, because it is the first thing a tax review examines. And the capital contribution has to match the articles and the FX registration; a shareholder loan sitting where capital should be is a finding, not a shortcut.
What lateness actually costs
- The abnormal-operation list. Public, and it blocks registration changes, equity transfers and, in practice, bank reviews.
- Fines. Modest per filing, but they accumulate across four filings.
- Tax credit rating. Late or missing filings reduce the company’s rating, which is used in tenders, bank facilities and some licence applications.
- The legal representative. Persistent non-compliance can restrict the representative personally, which matters for a foreign founder who may later apply for a visa or permanent residence.
- The exit. A company that wants to deregister cannot do so with open filings; the arrears surface at the tax clearance, at the worst possible moment.
The first year is different
A company registered in, say, October does not get a grace period. The annual report still has to be filed by 30 June for the stub period, the CIT settlement still covers the part-year, and the first audit covers from incorporation rather than twelve months. Two things shift:
- The audit is a stub-period audit, which is cheaper but still required before the settlement, and the auditor needs the establishment documents as well as the trading records.
- The July base reset may not apply yet if payroll started after July, which means the first full year of contributions begins on the following January’s payroll and the first July reset is the one that matters.
The failure pattern in year one is a founder who assumes “no revenue, nothing to file”. A company with no revenue still files, still reports, and still appears on the list if it does not.
Who owns which task
In a small WFOE, one person usually holds all of it, which is why it slips. The practical split is:
- Finance or the outsourced accountant — books, audit liaison, CIT settlement, payroll and the July base reset.
- Company secretary or admin — annual report, FDI report, FX registration, chops and the filing receipts.
- The advisor — the calendar, the cross-checks between filings, and the review before anything is submitted.
The cross-checks are where value sits: the capital in the annual report has to match the FX registration, the employees in the FDI report have to match the social-insurance record, and the profit in the tax settlement has to match the audited statements. A mismatch between two filings is a question waiting to be asked.
Build the file as you go
Keep the receipts: the annual report confirmation, the FDI and FX filing receipts, the audit report, the tax settlement, the payroll and social-insurance filings. A folder per year is enough. It is the difference between answering a query in a day and reconstructing a year.
The tax registration page covers the filing cycle these obligations run on, the company registration page covers the capital and structure being reported, and the deregistration guide covers the exit that has to clear the same records. Payroll and social-insurance filings start with the first hire, which the first-foreign-employee guide covers. To have the calendar mapped to your city and entity, contact an advisor.