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How should the "remarks column" of a fully digitalized e-invoice be filled in? Non-compliant filling will be rejected! There are also tax-related risks!

Published: 2024-04-26 15:45

Fully digitalized e-invoices are widely praised by taxpayers in pilot regions for their advantages of a simpler invoicing process, fully digitalized invoice information, fully simplified invoice format, automatic invoice delivery, integrated booking and archiving, and simplified red-letter invoice processing.

The issuance of fully digitalized e-invoices has become an issue of growing concern for financial personnel.

Unlike traditional tax-controlled invoices, fully digitalized e-invoices have different formats for each specific business type, and the question of how to fill in the remarks column also gives finance staff a headache.

Five specific businesses in fully digitalized e-invoices: construction services, freight transport services, real estate sales, real estate operating lease services, and passenger transport services. The "remarks column information" is a required field.

What risks will be faced for failing to fill in specific business fully digitalized e-invoices according to specifications?

The rules for filling in the "Remarks" column are reflected in multiple regulations, and we have summarized them for you.Let's take a look!


01 Four major risks of non-standard remarks column completion

I. Violation of Invoice Management Measures

Invoices shall be issued truthfully in one go for all copies in accordance with the prescribed time limits, order, columns, and content, and shall be stamped with the special invoice seal. Invoices issued by the issuer that do not comply with regulations shall not be used as financial reimbursement vouchers, and any unit or individual isRight to refuse acceptanceof.

Obtaining an invoice without remarks as required clearly constitutes obtaining non-compliant vouchers, violates invoice management regulations, and the tax authority will order correction.

Tax authorities may also, in accordance with the Measures of the People's Republic of China for the Administration of Invoices, conductPenalty.

Relevant policy: "Invoice Administration Measures of the People's Republic of China"


II. VAT risk

Where a taxpayer purchases goods, labor services, services, intangible assets, or real estate, and the value-added tax deduction vouchers obtained do not comply with laws, administrative regulations, or relevant provisions of the competent tax department of the State Council,Its input VAT amount shall not be deducted from output VAT.

VAT risk

Relevant policy: "Interim Regulations of the People's Republic of China on Value-Added Tax"


III. Corporate income tax risk

Invoices obtained by an enterprise that are filled out irregularly or do not comply with regulations shall not be used as pre-tax deduction vouchers for enterprise income tax,Cannot be deducted before corporate income tax.

Corporate income tax risk

Relevant policy: "Announcement of the State Taxation Administration on Issuing the <Measures for the Administration of Pre-tax Deduction Vouchers for Enterprise Income Tax>"


IV. Land value-added tax risk

After the business tax-to-VAT reform, VAT invoices obtained by land value-added tax taxpayers for construction and installation services shall, in accordance with the Announcement of the State Taxation Administration on Matters Concerning Tax Collection and Administration for Comprehensively Piloting the Replacement of Business Tax with VAT (State Taxation Administration Announcement No. 23 of 2016), beThe remarks column of the invoice shall indicate the name of the county (city, district) where the construction service occurred and the project name; otherwise, it shall not be included in the deductible amount for land value-added tax.

Land value-added tax risk

Relevant policy: "Announcement on Several Collection and Administration Provisions for Land Value-Added Tax after the Business Tax-to-VAT Reform"


02 Do all fully digitalized e-invoices need the remarks column filled in?

There are two cases:

1、 Those with explicit format requirements in regulations

It must be filled in the correct format. If the format is incorrect or the remarks are not filled in, the tax authorities will determine it as "false invoicing," and VAT deduction will not be allowed, nor will it be deductible before tax.

2、 Those without explicit format requirements in regulations

It is recommended to fill it in! Remarks serve as the informational link between the invoice and the real business, and supporting information related to the real business should be filled in as much as possible.


03 Five specific items of fully digitalized e-invoicesWhat are the standards for filling in the remarks column?

I. Construction services

Mandatory content in the remarks column of construction service invoices includes:

Place where construction services occur

Construction project name

Cross-prefecture (city) marker


II. Goods transportation services

Required contents in the remarks column of goods transportation services include:

Type of transport vehicle

Transport vehicle plate number

Place of Departure

Destination

Name of transported goods


III. Real Estate Sales

Mandatory items in the remarks column for real estate sales include:

Real estate address.

Area unit

Cross-prefecture (city) marker


IV. Real estate operating lease services.

Required contents in the remarks column of real estate operating lease service invoices include:

Real estate address.

Lease start and end

Cross-prefecture (city) marker

Property ownership certificate/real estate ownership certificate number

Area unit


V. Passenger transport services

Passenger transport service taxpayers fill in according to their own needs:

Place of departure

Destination

Information such as means of transportation



Beijing Kailing Technology Co., Ltd.——an enterprise business-finance-tax digitalization solution service provider.

Kailing Technology provides solutions for sales management systems, procurement management systems, output invoicing systems, input invoice collection systems, imaging management systems, financial posting systems, electronic accounting archives, fully digitalized e-invoice and Leqi interfaces and other businesses according to enterprise needs, professionally and efficiently helping enterprises transform and upgrade their business-finance-tax digital management.

If you have any business-finance-tax digital transformation needs, welcome to contact us. Beijing Kailing Technology will serve you wholeheartedly.

Passenger transport services


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Common Questions
For which businesses must the remarks column be filled in fully digitalized e-invoices? What are the risks of not filling it in?
For these 5 specific businesses — construction services, freight transport services, real estate sales, real estate operating lease services, and passenger transport services — the remarks column is mandatory. Failure to fill it in as required constitutes a non-compliant invoice, which may result in: input tax not being deductible, corporate income tax not being deductible before tax, land value-added tax not being included in deductible items, and possible penalties from tax authorities.
What content must be filled in the remarks column of construction service fully digitalized e-invoices?
Mandatory content in the remarks column of construction service fully digitalized e-invoices includes: place where construction services occur, construction project name, and cross-region (city) flag. Failure to fill in as required may be deemed as false invoicing, with VAT not deductible and no pre-tax deduction.
How to fill in the remarks column of the fully digitalized e-invoice for goods transportation services?
Required contents in the remarks column of the fully digitalized e-invoice for goods transportation services include: type of transport vehicle, license plate number of transport vehicle, place of departure, destination, and name of transported goods. Non-standard filling will make the invoice non-compliant and unusable for input VAT deduction and pre-tax deduction.
What should be filled in the remarks column of fully digitalized e-invoices for real estate sales and leasing?
Mandatory in the remarks column for real estate sales: real estate address, area unit, cross-region (city) marker. Mandatory in the remarks column for real estate operating lease services: real estate address, lease term start and end, cross-region (city) marker, property ownership certificate/real estate ownership certificate number, area unit. If not filled in or filled in incorrectly, the invoice is invalid, and the related costs and expenses may not be deducted.
For businesses where the remarks column of a fully digitalized e-invoice has no explicit format requirement, can it be left blank?
It is recommended to fill it in. Remarks serve as the informational link between the invoice and the real business, and supporting information related to the real business should be filled in as much as possible. Although regulations do not mandate it, complete filling helps avoid tax risks and ensures compliant use of invoices.
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