In 2025, the Third Inspection Bureau of the Beijing Municipal Tax Bureau announced a typical case: a Beijing trading company (hereinafter referred to as "Company A") was arrested by the Beijing Municipal Tax Bureau forAcceptance of fraudulent invoices and uncontrolled invoices without the required transfer of input taxesIn addition, the total amount of recovered taxes, late fees and penalties was$2.637 millionThe case exposed the typical tax risk of trading enterprises under the mode of "purchasing without invoice" and "low price and volume". The case exposes the typical tax risks of trading enterprises under the mode of "purchasing without invoice" and "low price and volume" - in the context of "Golden Tax V", which realizes the whole chain of "invoice flow, capital flow, goods flow and contract flow", any link of falsification will trigger the system warning. Under the background of "Golden Tax Phase V", which realizes the whole chain of "invoice flow, capital flow, goods flow and contract flow", any link of falsification will trigger the system's early warning.
Company A was established in 2023, registered in Fengtai District, Beijing, mainly engaged in wholesale of electronic components, customers are mostly small and medium-sized electronic product manufacturers. 2025 revenue of about 48 million yuan, gross profit margin of only 3% (industry average 8%-10%), belongs to the typical "thin profit, high sales" type of trading enterprises. It is a typical "thin profit, high sales" type of trading enterprise.
Acceptance of false invoicesFrom October 2024 to June 2025, Company A, in order to reduce procurement costs, obtained through intermediaries from three foreign enterprises (all of which have fled and lost contact) the following information126 specialized VAT invoicesThe total price and tax amounted to 13.8 million yuan, involving input tax of 1.59 million yuan. The invoice was for "integrated circuits", but the actual purchase was for "refurbished chips" (without proof of legal origin).
Uncontrolled invoices not transferredIn March 2025, Company A accepts a payment from Company B, an upstream company.42 specialized VAT invoices（Company A did not make input tax transfer in the current period according to the regulations, resulting in underpayment of VAT by 530,000 RMB.
false declarationCompany A deducts the full amount of input tax credit of RMB 1.59 million and deducts the inflated cost of RMB 12.21 million (RMB 13.8 million - RMB 1.59 million) before tax at the time of EIT settlement, thus underpaying the EIT by RMB 3,052,500 (RMB 12.21 million × 25%).
According to Article 63 (tax evasion) and Article 64 (fabrication of false tax basis) of the Tax Collection and Administration Law:
Recovery of taxes: VAT 2.12 million (1.59 million + 0.53 million) + CIT 3.0525 million =5,172,500.;
overdue fine: A daily charge of five ten thousandths of one percent of the late tax is added from the date the tax is late to the date of payment (approximately $465,000);
fine (monetary): A fine of 0.5 times the amount of the tax evaded (5,172,500 x 0.5 = 2,586,250) and a fine of 10,000 yuan for false declaration;
Total: $5,172,500 + $465,000 + $2,596,250 ≈ $2,637,000(Rounding in the text).
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Combined with the audit cases in Beijing in recent years, the core reasons for trading enterprises to be fined for invoice problems can be summarized into four categories:
The upstream of trading enterprises are mostly individual businessmen and small-scale suppliers, which are difficult to provide compliant invoices. company A chooses to "buy invoices to offset costs" to solve the "input gap", but ignores the three fatal characteristics of false invoicing:flow of funds backCompany A pays the invoicing party the "payment for goods" through the public account, and then the invoicing party transfers the funds back to the account of Company A's actual controller through a private account (as found by the Inspection Bureau through the comparison of bank flows);Cargo flow anomalies: The invoice shows "IC shipped from Shenzhen", but Company A actually receives the goods in Langfang, Hebei (no transportation certificate);The name of the product does not match the scope of businessCompany A does not have the qualification of "chip research and development" in its business license, but it accepts a large number of invoices for "integrated circuits" (Golden Tax Phase V automatically warns of "invoicing beyond the scope of business").
Runaway invoices refer to invoices issued by upstream enterprises that have been classified as "abnormal vouchers" by the tax authorities due to reasons such as evasion or cancellation. According to the regulations, the party to be invoiced shall, upon receipt of the Notice on Tax MattersWithin 10 working daysCompany A failed to process Company B's uncontrolled invoices in a timely manner due to a change in financial personnel, resulting in the accumulation of risk.
Company A's gross profit margin is only 3%, far lower than the industry average, in order to maintain profits, had to reduce costs through "false enhancement". The Audit Bureau pointed out that: "Low price competition cannot be the reason for violation of the law, enterprises need to optimize the supply chain (such as direct procurement with regular manufacturers) rather than buying tickets to solve the problem of inputs."
Compliant invoices need to meet the four streams of "contract flow (purchase and sales contracts), fund flow (public-to-public transfers), cargo flow (transportation documents), and invoice flow (the same product name and quantity)".A company's purchase contract does not match the invoice name, the funds flow back from the private sector, and there are no transportation documents, which is labeled as a "high-risk transaction" in the system. High Risk Transaction".
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White List Criteria::Blacklisting mechanismFor suppliers that "require cash transactions", "refuse to provide logistics slips" and "frequently change the main body of invoicing", we will directly terminate the cooperation and report to the tax authorities.
By the 5th of each month: Log in to Beijing Electronic Taxation Bureau → "Invoice Management" → "Abnormal Voucher Query" to check whether there are "uncontrolled invoices" and "canceled invoices". ";Per large purchase: Verify the authenticity of invoices through the "National VAT Invoice Verification Platform of the State Administration of Taxation" (enter the invoice code, number, invoice date, and the last 6 digits of the check code);quarterly reviewCompare "Purchase Amount and Invoices", "Sales Amount and Outgoing Invoices", "Invoice Amount and Bank Flow" to ensure that the three singles match.
Notification received: Upon receipt of the Notice on Tax Matters from the tax authorities (informing that the invoice is out of control), the deduction of input tax credit for the invoice will be stopped immediately;Appeals by proofIf the invoice is considered to be genuine (e.g., the upstream enterprise is temporarily out of contact due to the epidemic), it is necessary to submit the "Application for Verification of Abnormal Vouchers" within 10 working days, attaching evidence such as "contract, transportation bill, warehousing bill, bank current", etc. The invoice should be verified within 10 working days, and the invoices should be submitted within 10 working days;Transfer or back taxesIf it is verified that the invoice is out-of-control, it will be reported in the column "input tax amount transferred out" in the VAT return of the current period; if it is impossible to prove, it will be required to pay the tax and late payment fee.
business side: When the procurement department signs a contract, it should specify the "invoice issuance time (when the goods arrive at the ticket), product name and specification (consistent with the contract), tax rate (13%)", and request the "delivery note (stamped with the official seal of the supplier)";
financial side: Setting up an "invoice auditing post" and implementing "two-person review" for "large-value invoices (≥500,000 yuan), foreign invoices (across provinces), and sensitive product names (e.g., luxury goods, precious metals)";
management: Incorporate "invoice compliance rate" into KPIs (e.g., input invoice compliance rate ≥98%), and implement "one-vote veto" for non-compliance.
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An electronic trading company (Company B) in Daxing District, Beijing, was interviewed for accepting false invoices in 2025 and initiated corrective actions in 2026:
Step 1: Liquidate vendors: Elimination of 12 suppliers who could not provide compliant invoices, and signing of direct sourcing agreements with 5 regular manufacturers (the ratio of direct sourcing increased from 30% to 80%);
Step 2: System Empowerment: On-line "Invoice Management ERP System", automatic matching of "Purchase Order - Warehouse Receipt - Invoice - Payment Order", real-time warning of abnormal data (e.g. deviation between invoice amount and warehouse receipt amount >5%);
Step 3: Training and assessment: Monthly organization of procurement and financial personnel to learn the "invoice management approach", the assessment failed to suspend the business authority;effect: Input invoice compliance reached 100% in H1 2026, with no warnings from tax authorities, and gross margin rebounded to 7% (mid-industry level).
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The case of Company A warns us that in the era of "tax by numbers", the invoice problem of trading enterprises has been upgraded from a "financial flaw" to a "criminal risk" (the crime of false VAT invoices is punishable by up to life imprisonment). (the crime of false VAT invoicing is punishable by up to life imprisonment). For Beijing enterprises"Do not touch false invoicing" is the bottom line, "four streams of consistency" is the standard, "source compliance" is the fundamentalIt is recommended that enterprises: complete the "Supplier Compliance Checkup" by the end of March 2026; download the "Invoice Risk Self-Check" module of the "Beijing Tax App". Enterprises are recommended to: complete the "Supplier Compliance Checkup" by the end of March 2026 to eliminate high-risk partners; download the "Invoice Risk Self-Check" module of the "Beijing Tax" APP and scan enterprise invoice data every month; hire a tax firm to carry out a "Special Invoice Audit", focusing on checking large input invoices since 2024. Download the "Invoice Risk Self-Check" module of the "Beijing Taxation" APP and scan the invoice data of enterprises every month; hire a tax firm to carry out a "special invoice audit", focusing on the verification of large-value input invoices since 2024. Remember: invoice is not a "cost tool", but a "legal document". Compliance with the use of invoices is the only way for trading enterprises to walk more steadily and farther in the fierce competition.
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