Judging from the terms of this document, the "card purchasers and rechargers" here should include general taxpayers, small-scale taxpayers and individuals. Does that mean that in the future, ordinary taxpayers will not be allowed to ask for special VAT invoices if they buy related goods or services in the form of "prepaid cards"?
In order to illustrate this problem, let's first analyze why Announcement No.53 of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC) (20 16) stipulates that goods and services purchased with prepaid cards cannot be issued with special VAT invoices. The author analyzes the reasons as follows:
1. According to the operation process of single-use prepaid cards, the card purchaser and the top-up person may be the final consumers. The acts prohibited from issuing special VAT invoices as stipulated in Guo Shui Fa [1993] 150 include: (1) selling taxable items to consumers.
2. The card purchaser may not be the same as the recharger (payer) and the purchaser (payer) of the actual goods or services, especially in the group to which the enterprise belongs or the joining system of the same brand. The Notice of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC) on Strengthening the Administration of Value-added Tax Collection (Guo Shui Fa [1995] 192) stipulates that taxpayers who purchase goods or taxable services and pay transportation expenses must be consistent with the sales units and service providers who issue deduction certificates before they can declare the deduction of input tax, otherwise they will not be deducted.
According to the author's investigation, the single-use prepaid cards on the market at present can be divided into registered cards and bearer cards, and registered cards are mainly certificates issued by specific units to enjoy certain discounts. In view of this, if the buyer of the registered prepaid card is the buyer of the actual goods and services, and the buyer is the general taxpayer, and the card-issuing enterprise and the goods and services sales enterprise are the same party, it is unfair that the special VAT invoice cannot be issued, and this is not the original intention of Guo Shui Fa [20 16]53. The author believes that a special VAT invoice can be issued if the following conditions are met at the same time:
First, the card purchaser or recharger is a general taxpayer enterprise.
2. The card purchaser or recharger pays the advance payment (registered card) to the card selling enterprise in a non-cash way.
3. The end users of prepaid cards are the original card purchaser and the recharge person.
Four, the card purchaser or recharge in the original card selling enterprises to buy goods or services.
5. The seller of the card and the seller of goods and services are the same general taxpayer enterprise.
Six, the card seller shall not issue invoices to the card purchaser and the recharge, but shall issue invoices when the card purchaser purchases (sells) goods and recharges. The purpose of this clause is to ensure that the issuance of invoices conforms to the provisions of Item (4) of Article 38 of the Detailed Rules for the Implementation of the Provisional Regulations on Value-added Tax. When the commodity is pre-sold, it is the date when the commodity is issued.
The above "1" is to prove that the card purchaser or recharger is not the final consumer, and to ensure that the special VAT invoice cannot be issued according to the provisions of DocumentNo.. State Taxation Administration of The People's Republic of China 1993, in which: 1, selling taxable items to consumers. The above "II", "III", "IV" and "V" prove that the drawer complies with the Notice of State Taxation Administration of The People's Republic of China City, People's Republic of China (PRC) on Strengthening the Administration of VAT CollectionNo. 10. [1995] 192, namely "three streams in one", namely "goods, labor and taxable services", "capital flow" and "invoice flow".
Give an example to illustrate how to issue a special VAT invoice.
Dahua Liquor Wholesale Company, in order to attract large and medium-sized supermarkets and hotels to buy the "Yellow River Daqu Liquor" distributed by the company, took a 20% discount on prepaid cards in March (hereinafter referred to as registered Dahua prepaid cards). In that month, Supermarket A (general taxpayer) used bank deposit to buy "Dahua Prepaid Card" for 800,000 yuan. In February of this year, Supermarket A used the "Dahua Prepaid Card" to purchase goods at Dahua Liquor Wholesale Company at one time (without discount) for RMB 6,543.8+0,000. This case meets the above six conditions at the same time, and the financial treatment is as follows:
(1) Card selling enterprise (Dahua Company, also a sales enterprise)
1. When selling Dahua cards,
Borrow: 800,000 yuan from the bank.
Loan: advance payment-supermarket A ten thousand yuan.
2. When supermarket A finally purchases goods, it will issue a special VAT invoice.
Debit: advance payment-a supermarket 80
Loan: income from main business 68.37
Tax payable-VAT payable-output tax 1 1.63
(2) Card Buyers and Rechargers (Supermarket A)
1, pay the advance payment
Debit: Prepaid Account-Dahua Company 80
Loan: bank deposit 80
2. Buy commercial yellow rice wine
Borrow: Inventory goods 68.37
Taxes payable-VAT payable-input tax 1 1.63
Loan: advance payment-Dahua Company 80
reference data
Finance. Sohu [reference time 20 18- 1-9]