Six consecutive announcements in 2026, three things that dental clinics must changeValue added tax law, separation of technology and consumption, medical insurance flying inspection, compliance in the dental industry, Enyue Finance and Taxation focuses on corporate tax compliance, inspection response, financial outsourcing, and equity structure design. The first two articles wrote about the separation of technology and consumption (dismantling of cases that have been reverse checked) and the definition of tax exemption (five speed checklist). Many dental experts have responded, "I understand the reason, but is this urgent? We haven't started investigating yet." You are not the only one who has this feeling. But the problem is not whether you have checked locally or not, it is that the policy framework for 2026 has been thoroughly implemented
Six consecutive announcements in 2026, three things that dental clinics must change
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Six consecutive announcements in 2026, three things that dental clinics must change
You are not the only one who has this feeling. But the problem is not whether you checked locally or not, it'sThe policy framework for 2026 has completely changed。
From January this year until now, six policy documents directly related to dental clinics have been issued consecutively. It's not six notices, it's six legally binding documents. Everyone is tightening their stance and giving back to the past; Loose operation "; Draw a period.
1、 What exactly did the six announcements say
First, clarify the policies. Don't skip this paragraph, all subsequent operations are based on an understanding of these six files.
2、 The first thing: Separation of technology and consumption; Suggestion "; Becoming '; Legal Hard Threshold;
The first two articles have already discussed how to separate technology and consumption, so I won't repeat it here. Focus on why it must be changed this year.
The previous basis for separating technology and consumption was Article 41 of Annex 1 of Finance and Taxation [2016] No. 36; Those who also engage in tax-free projects should be accounted for separately;. This has always been the case, but the implementation criteria vary from place to place, and many outpatient clinics have been fine for ten years.
2026 has changed. Article 24 of the Value Added Tax Law includes tax exemption for medical services in the law, and Announcement No. 10 has written the tax exemption conditions into three hard thresholds.The consequences of not separating from '; May be investigated; Becoming '; Legally, it does not meet the conditions for tax exemption;.
This is not a matter of law enforcement standards, it is a matter of legal application. Previously, you said; I don't know what to divide; " No one cares about the local area; There is still room for discussion. Now that the law has been clearly written, the implementation regulations have defined the scope, and the conditions have been announced, without further distinction, it is; Consciously committing the crime;.
In practice, dental institutions have been investigated and taxed due to mixed charges. The amount is not small, but what's more troublesome is the combination of late fees and fines, which often add up to several times the amount of the supplementary tax itself.
3、 The second thing is that the charging and pricing cannot exceed the line
Announcement No. 10 has a particularly harsh condition for tax exemption:The fee shall not exceed the medical service price formulated by the medical security department at or above the municipal level.
Your outpatient fees cannot exceed the guidance price of local public hospitals. The excess amount is not exempt from tax and will be treated as taxable in full.
This has a significant impact on the private dental industry. The pricing of private dental clinics is already higher than that of public ones, with projects such as dental implants and orthodontics often costing tens of thousands of yuan, and many outpatient clinics have pricing far exceeding local guidance prices. I used to exceed it, no one checked your tax exemption eligibility. It's not possible now, the excess part needs to be fully taxed.
What's even more troublesome is that some clinics package and charge for planting projects, with one price covering surgical fees, implants, dental crowns, and bone powder, without separating technical and consumable costs, and charging beyond the guidance price. In this situation, the tax investigation is a double kill: the tax exemption qualification is not established and the tax is levied in full beyond the line.
There are two types of income that are definitely not exempt from taxes:
The first category,Medical Aesthetics ProjectCold light whitening, dental veneers (for cosmetic purposes), dental SPA, these belong to the category of; Profit oriented Beauty and Medical Care; The scope is explicitly excluded in Article 27 of the Implementation Regulations. Once you have done it, go ahead and declare it as taxable, don't think about mixing in with tax exemption declaration.
The second category,Special service fee, VIP urgent feeThe premium portion beyond the guidance price is not exempt from tax and will be treated as taxable.
4、 Third matter: Joint supervision of medical insurance and taxation, fully connected data
The first two things are; What should you do; The third thing is; What would happen if we don't do it;.
The biggest change in 2026 is not a single policy, but ratherIntegration of regulatory dataPreviously, those who checked taxes and those who checked medical insurance had their own responsibilities. It's different now.
Medical insurance flight tests focus on oral health. The National Healthcare Security Administration has notified that oral health has been listed as a key area for aerial testing. According to publicly available data from the National Healthcare Security Administration, in the first half of 2026, flying inspections will cover 227 cities and 2926 designated institutions nationwide, with dental examination being a high-frequency target. What are you looking for? Swapping projects, duplicate charges, and non bundled charges for technical consumption. The non differentiation of technical consumption is a newly added verification item this year, which has not been checked before.
Compare medical insurance data with tax data. How much did you settle for medical insurance and how much did you file for tax declaration? Two pairs, the difference will be directly alerted. There is a discrepancy between the medical insurance payment and declared income of dental institutions, which is automatically locked by the system and checked for accuracy.
The inspection of social security fees shall follow the tax enforcement procedures. Announcement No. 10 of 2026 by the State Administration of Taxation enables the inspection of social security fees to be carried out using the tools of the Tax Administration Law. If the dental clinic pays doctors social security based on the minimum base, the actual salary will be tens of thousands, and this gap is like paper in front of the fourth phase of the Golden Tax. If the deviation exceeds 40%, the online tax reporting function will be directly restricted.
Three regulatory loopholes are being tightened simultaneously, in plain language:Your medical insurance data, tax declaration, bank statements, and social security base are all on one website, and the system automatically compares and reports any differences.
5、 Landing action: 3 steps
Knowing what to change, you also need to know how to change it. Three steps, in order:
6、 10 self inspection checklist
Compare the following 10 items and check them one by one. If there is any uncertainty, it is recommended to consult a professional tax consultant:
Enyue Expert Core Suggestions
Author of this article: Founder
Founding Partner of Enyue Group | Senior Tax Planning Expert
With over 20 years of practical experience in financial and tax management, I have been deeply involved in the compliance architecture design of multiple companies planning to go public, and have unique insights into risk control in the digital regulatory environment.
