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Full Process Electronic Management of Electronic Credentials

In February 2021, in order to implement the spirit of the Central Economic Work Conference and fulfill the requirements of the "Notice of the State Administration of Taxation and other thirteen departments on promoting the reform of tax facilitation and optimizing the business environment of taxation," accelerate the application and promotion of value-added tax electronic invoices, reduce enterprise transaction costs, promote the work of "six guarantees" and "six stabilities," and support the development of the national digital economy, according to the relevant requirements of the State Council, based on the first two batches of pilot projects, the State Archives Administration, in conjunction with the Ministry of Finance, the Ministry of Commerce, and the State Administration of Taxation, plans to select another batch of units to carry out pilot work on the electronic reimbursement, accounting, and filing of value-added tax electronic invoices, to create a demonstration effect, further improve the systems and standards required for the development of the digital economy, and achieve the electronic collection, reimbursement, accounting, and filing of value-added tax electronic invoices.

In March 2023, in order to further promote the application and implementation of electronic invoices, the State Archives Administration, together with the Ministry of Finance, the Ministry of Commerce, and the State Administration of Taxation, summarized the experience of three batches of pilot projects on the electronic reimbursement, accounting, and filing of value-added tax electronic invoices. In accordance with relevant national laws, regulations, and standards, they compiled the "Guidelines for Full Process Electronic Management of Electronic Invoices."

The main process of electronic credentials is as follows:

Electronic Invoice Issuance

I. Application for Value-Added Tax Electronic Invoices

  1. Invoice Type Approval

New taxpayers should provide relevant tax information at the tax service hall or through online methods such as the electronic tax bureau to the competent tax authority to apply for approval of the invoice type. The competent tax authority will determine the types, quantities, invoice limits, etc., of value-added tax electronic invoices that taxpayers can issue in accordance with relevant regulations.

Taxpayers who have already obtained approval for the types of value-added tax electronic invoices, but whose current types, quantities, or invoice limits cannot meet their business needs, can provide relevant tax information at the tax service hall or through online methods to the competent tax authority for adjustment.

2. Issuance of Tax Control Devices

Apart from being included in the comprehensive digital electronic invoice pilot, other taxpayers issuing value-added tax invoices (including value-added tax electronic invoices) need to use tax control devices (commonly known as golden tax disks, tax control disks, and tax UKeys). According to the "Announcement of the State Administration of Taxation on Matters Concerning the Implementation of the Special Value-Added Tax Invoice Electronicization in New Taxpayers" (No. 22 of 2020), from the date of implementation of the electronicization of special value-added tax invoices in various regions, new taxpayers needing to issue value-added tax invoices in the local area will uniformly receive tax UKeys for invoicing. Tax authorities will provide tax UKeys to new taxpayers for free.

Before taxpayers use or reapply for tax control devices, the tax authorities need to initialize and issue the tax control devices, entering the taxpayers' basic information, approved invoice types, and other details into the devices. If there are changes to the taxpayers' basic information or approved invoice types, the tax control devices need to be reissued.

3. Receipt of Electronic Invoices

Taxpayers who have completed the procedures for value-added tax electronic invoices, such as invoice type approval and issuance of tax control devices, can receive electronic invoices either through the tax service hall or online channels such as value-added tax invoice software or the electronic tax bureau.

4. Preparation of Value-Added Tax Electronic Invoices

Taxpayers can use value-added tax invoice software to issue value-added tax electronic invoices. The golden tax disk corresponds to the software version for golden tax disks, the tax control disk corresponds to the software version for tax control disks, and the tax UKey corresponds to the software version for tax UKeys. The issuance process is as follows:

Log in to the value-added tax invoice software and enter the electronic invoice issuing interface.

Fill in the buyer's name, taxpayer identification number, address and telephone number, bank name and account number, project name, specifications, quantity, unit price, amount, tax rate, tax amount, and other information, then click the "Issue" button.

Deliver the value-added tax electronic invoice through methods such as email or QR codes for the recipient to access and download.

Taxpayers can use their own electronic invoice service platform that complies with the standards and specifications of the State Administration of Taxation or third-party electronic invoice service platforms to issue value-added tax electronic invoices.

Unlike paper invoices, value-added tax electronic invoices cannot be voided; if necessary, red invoices can be issued instead. In cases such as sales returns, invoice errors, cessation of taxable services, and sales allowances, where a red value-added tax electronic special invoice is needed, the relevant provisions of the "Announcement of the State Administration of Taxation on Matters Concerning the Implementation of the Special Value-Added Tax Invoice Electronicization in New Taxpayers" (No. 22 of 2020) shall apply.

II. Comprehensive Electronic Invoice Issuance

Relying on the newly established national unified electronic invoice service platform, tax authorities provide 24-hour online comprehensive digital electronic invoice issuance services to taxpayers for free. The following practices are from the pilot stage, and the official documents from the State Administration of Taxation after the pilot concludes shall prevail.

  1. Methods of Issuing Comprehensive Digital Electronic Invoices

For issuing comprehensive digital electronic invoices, taxpayers no longer need to obtain specialized tax control equipment. Specific invoice number ranges are eliminated through the "coded allocation" approach; after the invoice information is generated, a unique invoice number is automatically assigned by the system. Under the "credit granting" system, taxpayers are automatically granted a total invoice amount, achieving a "zero pre-setting" approach to invoicing. Based on the above characteristics of comprehensive digital electronic invoices, pilot taxpayers, after real-name verification, do not need to use specialized tax control equipment, apply for invoice type approval, or receive physical invoices. They can directly issue invoices using the electronic invoice service platform.

2. Delivery Methods of Comprehensive Digital Electronic Invoices

Pilot taxpayers can automatically deliver comprehensive digital electronic invoices to the recipient's tax digital account through the electronic invoice service platform. Alternatively, they can self-deliver comprehensive digital electronic invoices through methods such as email or QR codes. The delivery format (XML format or PDF, OFD format) can be selected by the delivering party as needed.

After the selling party successfully issues an invoice, the electronic invoice file and data are automatically delivered to the buyer's tax digital account by default. If the buyer is a party or government institution that has not entered an organizational code, or if the buyer is a natural person without an ID number, the system cannot deliver the invoice automatically. In such cases, the selling party can use self-delivery methods, such as querying the electronic invoice service platform's tax digital account, and then manually delivering the comprehensive digital electronic invoice through methods like email, QR codes, or exporting electronic files.

3. Issuance of Red Invoices

If pilot taxpayers encounter situations like invoice errors, sales returns, service interruptions, or sales allowances and need to issue red comprehensive digital electronic invoices, the following rules shall apply:

If the receiving party has not confirmed the use or recorded the entry of the value-added tax, the issuing party can issue a full red comprehensive digital electronic invoice without the need for confirmation from the receiving party.

If the receiving party has confirmed the use or recorded the entry, and the receiving party is also a pilot taxpayer, both parties can fill out a "Red Invoice Information Confirmation Form" (referred to as the "Confirmation Form," see Appendix G for the template) on the electronic invoice service platform. After mutual confirmation, the issuing party can issue a full or partial red comprehensive digital electronic invoice or a red paper invoice. If the receiving party is not a pilot taxpayer, after receiving a comprehensive digital electronic invoice from the electronic invoice service platform, they can either fill out the Confirmation Form on the comprehensive value-added tax invoice service platform or have the issuing party fill it out on the electronic invoice service platform. After mutual confirmation, the selling party can issue a red invoice. The information on the Confirmation Form should match the corresponding blue invoice information.

III. Issuance of Electronic Credentials that Comply with Accounting Data Standards

The Ministry of Finance, in collaboration with the State Administration of Taxation and other relevant departments, has conducted pilot work on electronic credentials and accounting data standards. This work realizes the complete process handling of electronic credential issuance, reception, parsing, reimbursement, entry, and storage based on accounting data standards. It addresses the "last mile" problem of paperless reimbursement and entry for electronic credentials. Units with the capability to issue electronic credentials that comply with accounting data standards should issue (deliver) electronic credentials that conform to the relevant business norms and standards of the relevant competent departments as required. They must ensure that all data and information of these electronic credentials are legal, authentic, and not tampered with. The issuing units send electronic credentials (including structured data files of electronic credentials that comply with accounting data standards, hereinafter referred to as "structured data files of electronic credentials") to the receiving units.

Receiving Electronic Invoices

I. Receiving Value-Added Tax Electronic Invoices

  1. Individual Dispersed Receipt

Individuals can download value-added tax electronic invoice files through methods such as email, QR codes, and the value-added tax invoice verification platform.

2. Bulk Download Receipt for Organizations

Organizations with a large volume of invoices can use the value-added tax invoice service platform to bulk download value-added tax electronic invoice files.

3. Naming of Electronic Invoices

When organizations bulk download electronic invoices, they should name the electronic invoice files according to a standardized format for easier processing. For example, naming could follow the format "Invoice Date - Invoice Code - Invoice Number."

II. Receiving Comprehensive Digital Electronic Invoices

  1. Individual Dispersed Receipt

Individuals can receive comprehensive digital electronic invoice files by methods such as email, QR codes, or exporting electronic files.

2. Organizational Download Receipt

After the selling party successfully issues an invoice, the system automatically delivers the comprehensive digital electronic invoice file and data to the buyer's tax digital account. The buyer can then download the required comprehensive digital electronic invoice files from their tax digital account.

3. Naming of Comprehensive Digital Electronic Invoices

When taxpayers download comprehensive digital electronic invoices, they should name the files according to a standardized format for easier processing. For example, naming could follow the format "dzm_comprehensive_digital_invoice_number_download_time."

III. Receiving Electronic Credentials that Comply with Accounting Data Standards

Receiving units that receive electronic credentials complying with accounting data standards should configure their software according to the required accounting data standards and relevant technical specifications. This ensures they have the capability to receive and parse electronic credentials. Upon receiving electronic credentials (including structured data files of electronic credentials), the receiving units should parse and process the structured data files for reimbursement, entry, and other accounting processes.

IV. Self-Verification of Content on Value-Added Tax Electronic Invoices

After receiving a value-added tax electronic invoice, the receiving party should verify whether the issued content on the invoice aligns with the actual economic transaction. If discrepancies are found, they should promptly contact the issuing party to request a reissued invoice. Self-verification of content alignment mainly involves checking whether the buyer's information, seller's information, project name, specifications, quantity, unit price, amount, tax rate, tax amount, and remarks on the value-added tax electronic invoice align with the actual economic transaction or contractual agreement.

V. Self-Verification of Content on Comprehensive Digital Electronic Invoices

After receiving a comprehensive digital electronic invoice, the receiving party should verify whether the issued content aligns with the actual economic transaction. If discrepancies are found, they should promptly contact the issuing party to request a reissued invoice. Self-verification of content alignment involves checking the "project name," specific business information (such as construction service information, real estate information, passenger transportation information, goods transportation information, etc.), invoice labels, business elements, and more, to ensure they align with the actual economic transaction or contractual agreement. Self-verification of content completeness mainly involves checking whether the received content on the comprehensive digital electronic invoice (such as buyer's information and tax number, unit price, written and numeric amounts, etc.) is complete.

Reimbursement of Electronic Invoices

I. Online Reimbursement of Value-Added Tax Electronic Invoices

For organizations with established business and reimbursement systems, processes such as collection, registration, verification, and approval of value-added tax electronic invoices can be completed online.

  1. Collection and Registration

The reimbursement requester completes an online reimbursement form and uploads the electronic invoices to the business system (invoice folder) to complete the collection process. Once collected, the business system automatically extracts the invoice information to generate electronic invoice data and performs a content check on the electronic invoice according to the "Self-Verification of Content on Value-Added Tax Electronic Invoices" requirements. Upon entering the reimbursement system, electronic invoices are assigned a unique identifier, completing the registration process.

2. Verification

Organizations should verify the authenticity of received electronic invoices to mitigate tax risks. Verification involves confirming the authenticity of the invoice using necessary information such as invoice code, invoice number, and invoice date.

3. Approval

Organizations that have implemented online reimbursement for electronic invoices typically perform reimbursement approval through the reimbursement system or OA system. The electronic invoices circulate within the system for approval, and the approval process generates electronic invoice approval workflow information, which can be used to generate reimbursement forms through interfaces or other methods.

4. Amount Confirmation

The reimbursement system processes approved electronic invoices, determines amounts according to rules, solidifies data, and generates payment data.

II. Offline Reimbursement of Value-Added Tax Electronic Invoices

For units without a reimbursement system in place or where the reimbursement system lacks approval functionality, processes such as reimbursement approval, collection, and registration of electronic invoices are generally conducted offline using paper-based reimbursement forms. Electronic invoices are transmitted through communication software. They are submitted by the reimbursement requester to the approver for approval, and accounting staff verifies and registers the electronic invoices during reimbursement.

  1. Approval

For offline approval of electronic invoice reimbursement, two methods are available: printing physical copies or not printing physical copies.

(1) Printing Physical Copies for Approval: The reimbursement requester prints the electronic invoice as a physical copy and submits it together with a filled-out reimbursement form and other original vouchers for offline approval. Simultaneously, the recipient of the electronic invoice transmits the original electronic file of the received electronic invoice through email or other communication software to the approving authority and then to the accounting staff. Before using this method, the organization should disclose the email addresses of the approver and the accounting staff for receiving electronic invoices.

(2) Approval without Printing Physical Copies: In this method, the reimbursement requester does not print a physical copy of the electronic invoice but directly fills out a paper-based reimbursement form. The approving authority only reviews the paper-based reimbursement form. The original electronic file of the electronic invoice is transmitted from the recipient to the approver and then to the accounting staff through email or other communication software.

2. Verification

(1) Verification through the National Value-Added Tax Invoice Verification Platform: Verify invoice information using the National Value-Added Tax Invoice Verification Platform (https://inv-veri.chinatax.gov.cn). The verification requires entering necessary information such as "Invoice Code," "Invoice Number," "Invoice Date," and the "Verification Code." After confirming the entered information, click the "Verify" button, and the system will display the verification results. If the entered information doesn't match the stored information in the tax system, it will display an inconsistency or no match message. If the entered information matches the stored information, the system will display the invoice details. Electronic invoices can only be reimbursed if their content matches the stored invoice content. The required verification items differ based on the invoice type.

(2) Verification through the Electronic Invoice Service Platform's Tax Digital Account: Log in to the electronic invoice service platform's tax digital account. This platform supports single invoice verification and batch invoice verification. In the single invoice verification mode, manually input invoice information for verification or upload PDF, OFD, XML, or images containing the QR code for verification. The verification results will display the invoice details. In the batch invoice verification mode, taxpayers can pre-process the required information for verification in a template data table and import it into the system for batch verification. The results will only show whether the verification results are consistent or not.

(3) Verification

Verification through the National Value-Added Tax Invoice Verification Platform: Log in to the National Value-Added Tax Invoice Verification Platform (https://inv-veri.chinatax.gov.cn) to verify invoice information. This platform requires entering information such as the "Invoice Code," "Invoice Number," "Invoice Date," and verification code. After confirming the information, click "Verify" to see the verification result. If the entered invoice information differs from the information stored in the tax system, it will display "Inconsistent" or "No Match." If the entered information matches the stored information, the system will display the invoice details. Reimbursement can only proceed if the information on the electronic invoice matches the tax system's stored information.

Verification through the Electronic Invoice Service Platform's Tax Digital Account: Log in to the electronic invoice service platform's tax digital account. This module supports single invoice verification and batch invoice verification. In the single invoice verification mode, manually input invoice information for verification, or upload PDF, OFD, XML, or image files containing the QR code for verification. The results will display the invoice details. In the batch invoice verification mode, taxpayers can pre-process invoice information in a template data table and import it for batch verification. The results will show whether the verification results are consistent or not.

3. Duplicate Checking

After verifying electronic invoices, accounting staff should perform a duplicate check against registered and reimbursed electronic invoices. If a received electronic invoice is found to be a duplicate of an already reimbursed and registered electronic invoice, reimbursement should be rejected, and the reimbursement requester should be notified promptly.

4. Registration

For verified electronic invoices, the electronic invoice custodian or responsible accounting staff should establish an electronic invoice collection folder named with "Year + Month" (e.g., as shown in the figure). This folder should be used to centralize stored electronic invoices and create a ledger of received electronic invoices.

5. Amount Confirmation

After approval, verification, and registration, accounting staff can confirm and authorize reimbursement amounts in accordance with organizational reimbursement management requirements and standard allowances for travel meal subsidies. Payments will be made as specified.

III. Reimbursement of Comprehensive Digital Electronic Invoices

The reimbursement process for comprehensive digital electronic invoices is the same as that for value-added tax electronic invoices.

If you are interested in expanding your operations in China and digitalize your HR operation, but are unsure where to start, contact us today. Our team of experts can provide the guidance and support you need to succeed in the Chinese market.

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