Editor's Note: The renewable resources, coal and other industries are generally natural persons and self-employed. Because natural individual retail investors cannot issue special VAT invoices, production enterprises usually add trading companies into the purchase and sale chain to realize their rights and interests deduction, and obtain special VAT invoices from trading companies. After the judicial interpretations of the two taxes were promulgated, some local courts held that the above situation was that the production enterprise realized the input deduction of the business that could not be deducted according to law through the fictitious trading company, which was a fictitious trading entity and constituted the crime of falsely issuing special invoices for value-added tax. Is the business model of the above-mentioned industries such as renewable resources a "fictitious transaction subject"? How to characterize trading companies and downstream production enterprises for the adjustment of business model with real transactions? This article will discuss this.

Editor's Note: Land Value Added Tax (LVAT) is a key tax for regulating the real estate market and participating in land revenue distribution, and the standardization and unification of its administration have always attracted much attention. Recently, the State Taxation Administration (STA) issued the Announcement on Several Administrative Guidelines for Land Value Added Tax (Exposure Draft) (hereinafter referred to as the "Announcement") to solicit public opinions. Prior to this, based on industry observations, Huashui Tax released the 2025 Compliance Report on Land Value Added Tax in the Real Estate Industry, which pointed out that current LVAT risks are highly concentrated in the standardized application of substantive tax elements. In practice, tax-enterprise disputes frequently arise over core tax system elements such as the period for collecting deductible items, exemption from LVAT for government land repossession, and the selection of allocation methods. The root cause lies in insufficient institutional supply. This Announcement serves as a crucial supplement to the national-level LVAT system, addressing concerns from frontline practice and market entities. This article will analyze each of the eight specific clauses of the Announcement, aiming to provide references for both tax authorities and taxpayers to accurately grasp the policy intent and actively participate in opinion feedback.

Surplus invoice fraud refers to the situation where a business with actual sales does not issue invoices to the real purchasers because the counterparties do not need them, resulting in surplus input tax credits, which are then used to issue invoices to third parties for a fee. In practice, there is controversy over how to characterize the act of issuing invoices to third parties with surplus invoices. This article aims to explore this issue by examining two similar judicial cases.

Editor's Note: The successive implementation of the "Announcement on Optimizing Matters Related to Enterprise Income Tax Prepayment Filings" (2025, No. 17) and the "Internet Platform Enterprise Tax-Related Information Reporting Provisions" is having a profound impact on the cross-border e-commerce sector. This is particularly evident after Amazon's public notification that it will quarterly report information related to Chinese sellers to the Chinese tax authorities, leading to many cross-border sellers receiving self-inspection notices from the tax authorities. This signifies that the new rules, through "information penetration" and "joint liability" mechanisms, have enabled the integration of tax authority data with internet platform data, fundamentally altering the tax regulatory logic for cross-border e-commerce export businesses. This article will analyze the tax challenges and response strategies faced by cross-border e-commerce from three dimensions: new regulations, risk identification, and compliance recommendations.

Editor's Note: Based on the deduction mechanism of VAT interlocking and invoice chain, the upstream false opening often leads to the risk that the invoices obtained by downstream bill-receiving enterprises face the transfer-out of input. There are many disputes about whether the downstream bill-receiving enterprises can file a reconsideration of the upstream documents based on their interests when the upstream enterprises have not filed a relief procedure for the documents that they have falsely opened. Recently, a provincial high court tried a similar case. The court held that the downstream bill-receiving enterprise had an interest in the tax treatment decision falsely made by the upstream tax bureau, and the bill-receiving enterprise had the right to file a reconsideration on the upstream treatment decision. This paper analyzes the case and further discusses the relief path of the bill-receiving enterprise for readers' reference.

Editor's Note: In recent years, cases of online freight platforms being involved in the false issuance of special VAT invoices have occurred frequently. Platforms such as Zhejiang Shenshi Shengxin and Sichuan Mouyida (a certain Yida in Sichuan) have seen case amounts often reaching hundreds of millions or even tens of billions of yuan. Downstream enterprises are mostly held accountable for the crime of falsely issuing special VAT invoices or illegally purchasing special invoices, while convictions and accountability based on the crime of tax evasion are relatively rare. This article introduces a latest judicial precedent of the court where obtaining invoices issued on behalf of oneself from an online freight platform led to a conviction of tax evasion. Combining this case, it analyzes the legal characterization of truthful invoicing on behalf of others, the boundary between false invoicing and tax evasion, and puts forward tax compliance suggestions for the logistics and transportation industry, providing practical references for transportation enterprises to respond to similar tax risks.

Fraudulent invoice cases often involve numerous parties and complex fund flows. Investigative authorities frequently engage third-party institutions to prepare audit reports to determine whether funds were recycled or invoice fees were paid, thereby transferring relevant parties for prosecution on charges of fraudulent invoicing. In practice, many prosecuting authorities tend to accept the conclusions of third-party institutions, sometimes even over-relying on audit reports to the extent of “substituting examination with certification”—a practice that severely violates fundamental principles of criminal procedure. This article analyzes and discusses audit reports through the lens of a specific false invoicing case.

Editor's Note: In June 2025, the "Rules on the Reporting of Tax-Related Information by Internet Platform Enterprises" and supporting tax policies were officially implemented, marking a new phase in China's e-commerce tax collection and management. By establishing platform information reporting obligations, the new regulations effectively address the long-standing challenge of "information asymmetry" in collection and management, placing higher demands on compliance management for various e-commerce operators. This article analyzes the core points of the new regulations, the identification of tax-related risks, and provides compliance recommendations, offering reference for market entities to adapt to the new regulatory environment.