How can non-Chinese companies minimize their risks and maximum their opportunities from China's tax reform? Jeff Olin, national managing partner, international taxes, at Grant Thornton LLP, advises companies to take advantage of "grandfathering" provisions that are still in effect before Jan. 1. "You can still go in and negotiate a tax holiday" until the new law takes effect, he said.

Longer term, non-Chinese companies need to prepare themselves for the rigorous new transfer-pricing documentation requirements, Olin said. That means keeping detailed records of transactions between your Chinese subsidiary and your U.S. and other offices. "Start planning now," Olin said. "Analyze your current flows and be prepared to file the documents required."

Chinese corporate tax returns are due each May 31 for companies that use the calendar year for their final return or within five months for other companies by the end of their fiscal year. "China wants you to show with your records that you are getting a reasonable return on the assets, capital and people you employ in China," Olin said. If you can prove that, you'll be paying your fair share of taxes to China."

"Any company doing or planning to do business in China would be well advised to review its current structure, paying particularly close attention to how it is invested and what changes are called for," said Peter Huels, managing director, Asia Pacific, at BDP International. "Many companies will be restructuring their investments and moving shareholding to new jurisdictions such as Singapore or Hong Kong, or to new holding structures to take advantage of the favorable treaties."