Recently, the person in charge of a state-owned enterprise was sentenced to 15 years in prison for environmental invoicing, and the case of the retrial was finally changed to not guilty entered the public eye, causing widespread discussion. The composition of the crime of false issuance of special VAT invoices must comply with the principle of subjective and objective consistency, that is, objectively there must be an act of false invoicing, and subjectively there must also be an intention to defraud the tax deduction, and the loss of national value-added tax has actually been caused. Where it does not have the subjective purpose of defrauding tax and does not cause the objective result of tax loss, it does not constitute the crime of false billing. However, over the years, there have been controversies over the fact that the crime of false opening is committed by acts, by purpose, and by result, resulting in the phenomenon of different judgments in the same case.