Case Introduction
A Shanghai-based technology company and its de facto manager were suspected of using another company to issue fraudulent Value-Added Tax (VAT) special invoices worth hundreds of millions of CNY without conducting any substantial business operations.
They were investigated by public security authorities for this crime, and the case was transferred to the procuratorate of a district in Shanghai for review and prosecution in early 2023. During the review and prosecution period, the company applied to the procuratorate for reform through compliance.
As a result, the procuratorate initiated a corporate compliance pilot and a third-party supervision and evaluation mechanism. In May 2023, they invited a panel of senior legal professors and lawyers to conduct compliance supervision and inspection of the company.This process has been publicly disclosed.