On the issue of “export invoice”, these nine questions should be clarified at one time!

        This article is an answer to the relevant questions on the practical level of export invoices for reference only. If the competent tax authorities have special requirements, the requirements of the tax authorities shall prevail.

        I. What are the types of export invoices?

        The confirmation of export income needs to be accompanied by export invoices. From a national perspective, export invoices can be roughly divided into three types: commercial invoices (CI), general machine-printed invoices, and VAT ordinary invoices (paper invoices, electronic invoices, and all-electronic invoices).

        1. COMMERCIAL INVOICE is the basis for the bookkeeping of both the buyer and the seller, and is also the general description of the import and export customs declaration and tax payment. This invoice is usually prepared by the salesman, and does not need to be prepared separately by the finance department.

        2. General machine-printed invoice: It is a traditional special export invoice, which has been canceled in most regions at present.

        3. Ordinary VAT invoices (paper invoices, electronic invoices, all-electronic invoices) are issued by most enterprises at present.

        Note: Since December 1, 2021, the pilot project of fully digital electronic invoice (full electronic invoice) has been carried out among some taxpayers in Shanghai, Guangzhou, Foshan, Hengqin Guangdong-Macao Deep Cooperation Zone and Hohhot.

        II. Is it necessary to issue export invoices for all export tax refund income? Is it feasible to replace it with commercial invoice (CI)?

        According to the regulations, export invoices are required for export income. The export invoices here refer to VAT ordinary invoices (including electronic invoices and full electronic invoices). In practice, foreign trade enterprises do not issue export invoices, and most tax authorities do not require them. Production enterprises generally require export invoices. Why?

        Because the calculation of tax credits and refunds of production enterprises is closely related to the sales of tax credits and refunds. If the income is inaccurate, it will directly affect the amount of tax refunds. The tax refunds of foreign trade enterprises are calculated according to the special invoices for purchase value-added tax. This is also the reason why some regions of foreign trade enterprises require to open the tax refunds, and some regions require not to open the tax refunds!

        From the perspective of supervision, the invoicing station can accurately obtain the sales volume of enterprises, facilitate the verification of statistical data from the customs, and also remind enterprises to confirm the revenue in time, mainly as a reminder. In practice, production enterprises should issue export invoices in strict accordance with the requirements. Whether foreign trade enterprises issue export invoices according to the requirements of the competent tax authorities, if not, can directly use commercial invoices (CI) as the entry documents.

        III. How to select the bookkeeping exchange rate when issuing export invoices?

        For the issuance of export invoices, it is recommended to choose the middle rate of RMB exchange rate on the first day of the month of export, and it is not recommended to use the middle rate of RMB exchange rate on the day of sales.

        The central parity rate of RMB exchange rate can be inquired through the websites of “China Foreign Exchange Trading Center”, “People’s Bank of China”, “Bank of China”, “State Administration of Foreign Exchange”, etc. For convenience, it is recommended to inquire through the website of “State Administration of Foreign Exchange”.

        IV. Is the confirmation of export tax rebate income accurate, completely based on the export date?

        Not completely accurate. The recognition of export revenue should be confirmed under the conditions that conform to the accounting standards or the accounting standards for small enterprises. In practice, it is not easy to recognize revenue in full accordance with the accounting standards or the accounting standards for small enterprises. In order to reduce the risk of tax, most export enterprises take the second place and choose to recognize it in the current month of export. It is quite acceptable for tax and enterprises to recognize income in the month of export, but it must be clear that it is not completely accurate to recognize income completely according to the export date!

        V. Foreign trade enterprises purchase a batch of goods from multiple suppliers, and the commodity names of the purchase invoices obtained are consistent, but the commodity categories are different. How to select the commodity categories when issuing export invoices?

        For the same batch of export goods, the commodity names of invoices issued by multiple suppliers are consistent, and the commodity categories are inconsistent. If the commodity categories issued are not materially wrong, it is also no problem. Export enterprises can choose the most appropriate category of goods to issue export invoices according to their own judgment. If it is difficult to judge the truth, they can issue export invoices according to the category of goods with the largest amount of purchase invoices.

        VI. What if the RMB amount of a single customs declaration exceeds the invoicing limit of the ordinary VAT invoice (excluding the all-electric invoice)?

        If it is regular, export enterprises can apply for an increase. If no increase is applied for and the RMB amount of a single customs declaration exceeds the invoicing limit of the invoice, multiple ordinary VAT invoices can be issued. The invoicing suggestions are as follows:

        1. It is recommended that the invoice be consecutively numbered when issuing.

        2. The total amount (the amount corresponding to the promissory note) can be filled in the FOB of the export amount in the remarks column. For example, the total amount of the export declaration is 20000 US dollars. Due to the limitation of the invoicing amount, the export enterprise issues two ordinary VAT invoices to confirm the sales revenue, each of which is 10000 US dollars. The suggestions for filling in the remarks column are as follows: the export amount FOB: 20000 US dollars (promissory note amount: 10000 US dollars).

        VII. The export of a batch of goods in September meets the conditions for revenue recognition. Because of negligence, revenue is recognized in December. Should the bookkeeping exchange rate for revenue recognition in December be September or December?

        It is recommended to use the bookkeeping exchange rate in September.

        VIII. Is it allowed to recognize the export tax rebate income across the year?

        The recognition of export tax rebate income is not special, and the conditions for revenue recognition in accordance with the accounting standards or the accounting standards for small enterprises should be recognized. If the export does not meet the conditions for revenue recognition in the current month, it will only meet the conditions in the next year. There is no problem to recognize the income across the year, otherwise it is not allowed. The main issue involved in the tax inspection is the enterprise income tax.

        In practice, some goods were declared close to the end of the year, and the data could not be found at the electronic port at the end of December of that year. It was found that the export date was December of last year, and there was no problem in revenue recognition in January of the next year. If it can be determined that the goods have indeed been sent and the data can not be found at the electronic port, it is also possible to directly recognize the revenue. The practice should be handled according to the specific situation, and the “malicious” phenomenon should not occur and the revenue should not be recognized later.

        IX. If the foreign trade enterprise does not obtain the purchase invoice for the export goods, can it obtain the purchase invoice to reconfirm the income?

        If the conditions for revenue recognition are met, the sales revenue should be recognized, which has no direct relationship with whether to obtain the purchase invoice. The goods have been exported (meeting the conditions for revenue recognition) and the revenue has been recognized, but the purchase invoice has not been obtained. How to handle the accounting?

        Here, we have to mention “estimated receipt”. Estimated receipt refers to that the goods have been received or sold in the current month, but the purchase invoice has not been received for various reasons. At the end of the month, in order to correctly calculate the cost of the enterprise, we need to estimate this part of the inventory into the account, which can be simply understood as the arrival of the invoice has not arrived. For example, if you buy a batch of export goods with tax refund, the amount of goods excluding tax is 10000, and the tax amount is 1300. The goods have been exported, but the invoice has not been received.

        1. Estimated receipt, accounting treatment is as follows:

        Debit:Goods in stock 10000

        Credit: Accounts payable – estimated 10000

        Note: The estimated amount should be based on the tax-exclusive amount of the goods. Since no VAT special invoice has been obtained, there is no problem of the estimated input tax.

        2. When receiving the purchase invoice, offset the estimation, and the accounting treatment is as follows:

        Debit:Goods in stock 10000

        Credit: Accounts payable – estimated 10000

        3. The accounting treatment is as follows:

        Debit:Goods in stock 10000

        Debit: Taxes payable – VAT payable (input tax) 1300

        Credit: accounts payable – supplier 13000

Article source：Comprehensive service network for export tax refund