Tax Official Q&A‖How are the quantity collected and invoice issuance limit for VAT electronic special invoices determined?

1.We are a newly established enterprise and would like to understand how the quantity of electronic special VAT invoices obtained and the invoicing limit are determined？

Answer: According to the Announcement of the State Taxation Administration on Matters Concerning the Implementation of Electronic Special VAT Invoices for Newly Established Taxpayers (State Taxation Administration Announcement No. 22 of 2020): tax authorities shall determine the quantity of special VAT invoices a taxpayer may collect based on the combined total of electronic special invoices and paper special invoices. The maximum invoicing limit for special VAT invoices (VAT tax control system) shall be the same for electronic special invoices and paper special invoices.

According to the Interpretation of the Announcement of the State Taxation Administration on Matters Concerning the Implementation of Electronic Special VAT Invoices for New Taxpayers and the Announcement of the State Taxation Administration on Matters Concerning the First Application for VAT Invoices by New Taxpayers (No. 29 of 2018), when a tax authority processes invoice type verification for a new taxpayer applying for VAT invoices for the first time, the maximum invoicing limit for special VAT invoices shall not exceed 100,000 yuan, and the maximum monthly quantity obtained shall not exceed 25 copies. Provincial tax authorities may, within this range and in light of the taxpayer's tax risk level, determine their own standards for invoice type verification for new taxpayers applying for VAT invoices for the first time.

Electronic special invoices and paper special invoices both belong to VAT special invoices. The maximum invoicing limit for VAT special invoices approved by the tax authority applies simultaneously to electronic special invoices and paper special invoices used by taxpayers, and the two remain consistent.

Newly established taxpayers implementing electronic special VAT invoices may, within the maximum monthly quantity of VAT special invoices approved by the tax authority, determine the quantity of electronic special invoices and paper special invoices to be obtained separately according to their own needs. After the tax authority approves the maximum invoice issuance limit and quantity of VAT special invoices, newly established taxpayers implementing electronic special VAT invoices may apply for "increase in version and increase in quantity" according to production and operation needsvolume."

2.Our company is a general VAT taxpayer. An employee on a business trip obtains an electronic ticket itinerary. The itinerary separately indicates a rebooking fee. Can the rebooking fee be calculated as purchased passenger transport services for input VAT deduction?

Yes. The change fee listed on the air transport electronic ticket itinerary and the change fee listed on the railway ticket both fall within the scope of the total price and off-price charges obtained by taxpayers providing transport services, and can be handled in accordance with the Announcement of the Ministry of Finance, State Taxation Administration, and General Administration of Customs on Policies Related to Deepening VAT Reform.（Ministry of Finance, State Taxation Administration, General Administration of Customs Announcement No. 39 of 2019）Calculate the deductible input tax amount in accordance with the relevant provisions of Article 6.

3.Our company is a general VAT taxpayer. It invites university experts to conduct employee training and pays for their round-trip air tickets. Can the input VAT be deducted as passenger transport services?？

No. According to the Announcement of the State Administration of Taxation on VAT Collection and Administration Issues Concerning the Deduction of Input Tax on Domestic Passenger Transport Services and Other Matters, State Taxation Administration Announcement No. 31 of 2019）Where a general VAT taxpayer purchases domestic passenger transport services, the input tax is allowed to be deducted from output tax. This refers to domestic passenger transport expenses incurred by employees who have established a lawful employment relationship with the entity, and the input tax on such expenses is allowed to be deducted. If the taxpayer pays passenger transport expenses for non-employees, such expenses cannot be included in the deduction scope.。

Source: State Taxation Administration

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