【政策】关于印发《上海市税务局税收事先裁定工作管理办法》的通知沪税办发〔2025〕13号

Core Viewpoint - The article discusses the revised management measures for tax pre-ruling in Shanghai, aimed at enhancing the certainty of tax policy application and providing personalized tax services to enterprises [2][3]. Group 1: General Principles - The purpose of the management measures is to standardize the tax pre-ruling work in the city and improve the certainty of tax policy application [2]. - Tax pre-ruling is defined as a service where enterprises can apply for written opinions on the application of tax laws for specific complex tax matters [3]. Group 2: Applicable Objects and Scope - The measures apply to tax matters occurring within the city [4]. - Certain matters are excluded from the scope of pre-ruling, including those without a definite project plan or those that do not have a reasonable commercial purpose [5][7]. Group 3: Application and Acceptance - The applicant for a tax pre-ruling must be the entity directly liable for tax obligations, and the application is submitted to the competent tax authority [6]. - The application must include a detailed application form, a knowledge letter, and any necessary supporting documents [6]. Group 4: Review and Ruling - The competent tax authority is responsible for coordinating the review of applications and must provide initial processing opinions within 30 days of acceptance [10][11]. - The ruling must be documented in a tax pre-ruling opinion letter, which is subject to review by the tax bureau [13][14]. Group 5: Ruling Application - The pre-ruling opinion is applicable only if the submitted materials are legal, truthful, and consistent with actual tax matters [17]. - If there are substantial changes in the matters after the ruling, the applicant must notify the tax authority within 30 days [18]. Group 6: Additional Provisions - The Shanghai tax authority promotes cross-provincial cooperation to develop a unified approach to tax pre-ruling for large enterprises in the Yangtze River Delta [22]. - Tax authorities must maintain confidentiality regarding the applicant's business secrets and personal privacy [23].