Quick Q&A on Taxpayers' Compliant Issuance of Invoices (Part 1)

 

 

Issued by:    State Taxation Administration
Release Date:    April 24, 2026
Links:  https://www.chinatax.gov.cn/chinatax/c102414/c5249173/content.html

 

To guide taxpayers in issuing invoices in compliance with regulations and to prevent issues such as false invoicing, tax fraud, and economic problems related to invoicing, the State Taxation Administration has released a Q&A and a list of positive and negative practices for issuing compliant invoices. These documents clarify the compliance boundaries from four dimensions: the invoicing entity, the transaction, the invoice face content, and the time limit. The main contents are as follows:
1.    Positive List (16 items) – the “benchmark” for compliant invoicing. Taxpayers may refer to the positive list to determine whether an invoice is compliant across the four dimensions:
(1)   Compliance of the invoicing and invoice-receiving entities: The entity is duly registered according to law, has a normal tax status, and possesses operational capacity commensurate with the scale of invoicing. The information of the “six roles” (legal representative, financial responsible person, tax filer, investor, invoice receiver, and invoice issuer) is true and valid. Invoices are issued by tax personnel who have completed real‑name identity verification in the Tax Pre-collection Phase.
(2)   Compliance of production and business operations: The transaction has a reasonable commercial purpose, is genuine, involves fair pricing, and aligns with business logic. In principle, the “four flows are consistent” (contract flow, goods/service flow, fund flow, and invoice flow), and the supporting documentation is complete.
(3)   Compliance of invoice face information elements: The correct type of invoice is used, all required information on the invoice face is filled in completely and accurately, and red-letter invoices (credit notes) are issued in accordance with prescribed procedures.
(4)   Compliance of invoice issuance timing: Invoices are issued strictly at the point when revenue is recognized, neither earlier nor later.
2.    Negative List (28 items) – the “warning line” for non‑compliant invoicing, mainly including:
(1)   Entity non‑compliance: false registration, shell companies or “four‑lacks” enterprises (no actual office premises, no employees enrolled in social insurance, no utility consumption, no fixed assets); using private bank accounts to conceal income and facilitate fund backflows; inverted purchase and sales (e.g., cost of goods sold higher than sales price), abnormal tax burdens, and other similar situations.
(2)   Business non‑compliance: issuing invoices for fictitious transactions, circular invoicing without a reasonable commercial purpose, issuing invoices under a borrowed name or through affiliation, artificially splitting transactions, fabricating transaction links, inconsistency among the “four flows”, mismatch between input and output tax, an obvious mismatch between business premises, personnel, etc. and the scale of invoicing, and other similar situations.
(3)   Invoice face non‑compliance: missing, incomplete, or false information; incorrect application of tax rates; non‑compliant remarks column; improper red-letter invoicing/voiding, etc.
(4)   Timing non‑compliance: issuing invoices earlier or later to adjust revenue, refusing to issue invoices, a serious disconnect between the timing of invoice issuance and the underlying transaction, etc.

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