Tax certainty redefined: Shanghai formalizes advance tax ruling measures
Shanghai has moved from a pilot approach to a formally implemented stage with the introduction of a new normative document for advanced tax rulings (ATR). Building on the experience of the earlier trial measures, the new measures expand the eligible scopes and applicants of ATR, refine the application procedures and clarify the binding effect of the ATR.
On October 24, 2025, the Shanghai Municipal Tax Bureau issued the Administrative Measures for advanced tax rulings (the New ATR Measures), which simultaneously repealed the former trial measures for ATR introduced on December 29, 2023. By formalizing and enhancing what was previously a trial mechanism, the New ATR Measures further standardize the ATR tax services in Shanghai and will provide more practical experience for the nationwide implementation of ATR at a later stage.
- Highlights of Trial ATR Measures
- Similarities and differences between the New ATR Measures and Trial ATR Measures
- Closing remark
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