Answers to tax issues of commercial factoring companies after the “VAT to VAT” reform

港信通-今天给大家解答下商业保理公司”Business tax to value-added tax”related tax issues，Let’s learn together!

one、 After the business tax to value-added tax，A special value-added tax invoice was issued，How to void or flush?

1. If it is discovered that month，The company has not copied taxes yet，The buyer has not yet taken away the invoice deduction coupon，You can cancel it and reopen it yourself;
2. If the company has copied the tax，The buyer has not yet certified and deducted，The company will apply to the competent state tax bureau for the "Information Form for Issuing Red Letter Special Value-Added Tax Invoices"，Select "Buyer Not Deducted";After our company received the red-letter invoice notice from the IRS,，Issuing a red letter invoice。
3. If the company has copied the tax，The buyer has been certified or deducted，The purchaser shall apply to its competent state tax office for the "Information Form for Issuance of Special Red Letter Value-Added Tax Invoices";After the buyer gets the red-letter invoice notice from the IRS,，Submit it to our company to issue a red invoice。two、After the business tax to value-added tax，What is the tax rate in the factoring industry??In practice, there are two categories：Commercial factoring and bank factoring。Bank factoring financing，Processed by loan service;Tax rate 6%。

commercial factoring：

1. Factoring Financing，Processed by loan service，Tax rate 6%，Special VAT invoices cannot be issued;
2. Factoring services，Financial services processed on a direct charge basis，Tax rate 6%，Special value-added tax invoices can be issued;
3. Transfer of claims receivable，Treated as financial product transfer，Calculate sales after netting off profits and losses within one year，Tax rate 6%，Special VAT invoices cannot be issued。

three、After the business tax to value-added tax，Corporate income tax original local tax，Whether it should be included in the national tax?Not included in the national tax collection and management for the time being、Does the preferential corporate income tax policy for factoring companies comply with the 15% preferential corporate income tax guidelines in Qianhai??Factoring belongs to the financial services industry。Qianhai Enterprise Income Tax Preferential Catalog(Finance and Taxation [2014] Document No. 26)，No 15% corporate income tax concession is given to the financial services industry。

five、The factoring company cannot obtain enough input tax invoices，If the actual tax burden does not decrease but increases，Are there any transitional policies or tax incentives??This time the business tax to value-added tax reform did not provide “financial support policies”。therefore，All enterprises must be familiar with how the national tax system is designed to ensure that the “financial services industry” only increases rather than decreases.，And implement this system design into the company's own value-added tax management situation，Implement with customers、In business negotiations with suppliers。

six、After the business tax to value-added tax，Whether the previous preferential tax policy for difference taxation of business tax continues in value-added tax? ?Basic continuation，but

Require

It is higher than the difference in business tax：

1. There must be a Ministry of Finance、Document regulations of the State Administration of Taxation，Not local enough;
2. There are specific documents for the difference

Require

。should be obtained in compliance with the law、Valid certificates stipulated by administrative regulations and the State Administration of Taxation。otherwise，No deduction allowed。

The above voucher refers to the invoice、Overseas receipt documents(Confirmation from an overseas notary institution may be required.)、tax payment voucher、Provincial level and above(Including provincial level)finance department supervisor(print)financial bills, etc.。

1. The above-mentioned certificates obtained by taxpayers are value-added tax deduction certificates.，The input tax cannot be deducted from the output tax。

seven、Loans obtained from financial institutions、Funds obtained from bond issuance、Reasons why legal and valid interest vouchers obtained from funds obtained from other institutions cannot deduct VAT input tax and whether there are solutions?Note：Funds from bond issuance are not income，Not all prices and extras included in sales

cost

。

Caishui [2025] No. 36 enumerates “prohibited deduction items”—purchased passenger transportation services、Loan services、catering services、Resident daily services and entertainment services。These services all have a common feature，There is no distinction between public and private matters，Difficult to collect and manage，If deductions are allowed, it will have a great negative impact on market order.。

eight、Whether the capital cost paid by a factoring company to obtain funds from the parent company or within the group can be deducted from input tax??Borrowing interest obtained by the parent company or group，Is it tax-free??The capital cost paid by the factoring company to obtain funds from the parent company or within the group is loan interest.

cost

，Unable to obtain special VAT invoice，Input tax is not deductible。

Borrowing interest obtained by the parent company or group，Is it tax-free?，Depends on whether it meets relevant conditions：In the VAT exemption clause，The only thing that does not use "financial institutions" is the unified borrowing and returning business of "enterprise groups"、"Enterprise Groups" in the process of borrowing and returning，According to the "Interim Provisions on Enterprise Group Registration and Management"，It refers to parent and subsidiary companies with capital as the main link.，A parent company that uses the group's articles of association as a common code of conduct、Subsidiaries、A consortium of corporate entities with a certain scale composed of joint-stock companies and other member companies or institutions.。

In accordance with the policies and regulations of Finance and Taxation [2025] No. 36，The unified borrowing and returning business is in progress，The borrowing interest rate paid by the borrower shall not be higher than the borrowing interest rate paid to the financial institution or the bond coupon rate paid.，Interest collected from enterprise groups or subordinate units within the group，VAT exempt。

If the interest charged by the borrower to the unit using the funds is unified，Higher than the borrowing interest rate paid by financial institutions or the bond coupon rate paid，It should be considered as an on-lending business，Pay VAT in full。Nine、Is the transfer of commercial bills considered a financial product transfer??belong。The transfer of financial products refers to the transfer of foreign exchange、Business activities other than ownership of cargo futures and other financial commodities。

Other financial products include funds、trust、Transfer of various asset management products such as financial products and respective financial derivatives。

ten、Assuming a note of 1 million，The factoring purchase price is 950,000，The selling price transferred to a third party is 960,000，Should the factor issue a VAT of RMB 10,000 or a special VAT invoice of RMB 50,000?，If it is a special ticket，Can a third-party institution issue a special VAT invoice of RMB 40,000 to the factoring agent??Can the invoice factor make input deductions??Financial product transfer，Special VAT invoices are not allowed to be issued，It covers all aspects of financial product transfer。

eleven、commodity repurchase bonds，Essentially a loan business，Income determination should be based on the loan term。

Tax liability is incurred each quarter when interest is accrued，Or when the commercial paper repurchases the creditor's rights?，Or when repurchasing，other side

Require

Issue an invoice，When issuing an invoice，Is it the tax time??The principle of judging the time when tax liability occurs is：Taxable activity occurs—receipt of sales items、or obtain a receipt for requesting sales items(Usually the time specified in the contract) Issue invoice first：On the day when the invoice is issued,，The above tax liability occurs when interest is accrued each quarter.;If the invoice is issued first，The day the invoice is issued。

twelve、Commercial factoring company，Is the VAT paid monthly or quarterly??According to the provisions of Caishui [2025] No. 36：small taxpayer、bank、finance company、trust company、Credit unions and other taxpayers specified by the Ministry of Finance and Economics and the State Administration of Taxation，Pay VAT quarterly。Commercial factoring company，If you are a small-scale taxpayer，then declare and pay quarterly;If you are a general taxpayer，Then declare and pay monthly。

Thirteen、At present, after financial companies issue loans,，Interest receivable and uncollected after 90 days from the interest settlement date will not be subject to VAT for the time being.，Can this provision be used by commercial factoring companies??Can。

Provisions of Finance and Taxation [2025] No. 36：After a financial company issues a loan，Interest receivable and uncollected within 90 days from the analysis date shall be subject to VAT according to current regulations.，Interest receivable and uncollected after 90 days from the interest settlement date will not be subject to VAT for the time being.，VAT will be paid according to regulations when the interest is actually received.。

fourteen、Tax control machine for special VAT invoices，Does the Golden Tax Card have to be in Shenzhen?，How to deal with this kind of remote office??The management of special tax control equipment is compared with the management of invoices，That is, except for special circumstances specified by the taxation department of the State Council，No unit or individual is allowed to carry items across designated use areas.、Postage and shipping。

fifteen、Input deductions，Because bank loan interest cannot be deducted，Where can other things be deducted??office computer、Decoration, etc.?Is there any way to convert the bank loan interest into a deductible item??Does the VAT invoice have to be received after May 1 to be deducted??

1. The scope document of deductible and non-deductible items has been clarified，Please refer to。
2. For prohibited conduct，It is not recommended to play the game on the edge.，At the same time, tax planning is not within the scope of the tax bureau.。
3. The deductible receipt date must be determined based on the time when you become a general taxpayer.。If you still want to know more about this aspect，Welcome to consult Hong Kong Xintong at any time!

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