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Establishing a VAT Monitoring System for China

21 January 2014   (0 Comments)
Posted by: Author: Chet Scheltema
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Author: Chet Scheltema (Dezan Shira & Associates)

China has rapidly implemented value-added tax reform over the last two years, and it has pledged to complete the reform by finally extending it even to the financial services and real estate industries by 2015. 

While value-added tax systems have grown in popularity worldwide over the last thirty years as a new source of dependable tax revenue (reportedly even US presidents Barak Obama and Richard Nixon briefly considered it), the Chinese value-added tax (VAT) system is unique and far more intricate and resource-consuming than normal. It is heavily dependent upon printed VAT invoices that can only be issued and used by resort to elaborate verification processes designed to ensure tax collection and to curtail fraud. 

Failure to effectively manage the system can result in substantial tax liabilities that may wholly consume already thin profit margins.Therefore, it is critical for every foreign invested enterprise in China (i) to plan for the impact of VAT from the very beginning, (ii) to establish an independent internal (or outsourced) system to monitor and manage the company’s VAT position, and (iii) for senior enterprise leaders to stay abreast of the company’s VAT position and to consider it when transacting business.

The Chinese VAT system has numerous hazards to ensnare an unwary foreign investor, and examples of several are briefly presented here. On a very foundational level, the most important initial step to effectively managing the Chinese VAT system is for a foreign invested enterprise to attain "general taxpayer status.” Value-added tax is intended to be imposed on nearly every business transaction not specifically exempted or otherwise excluded, and the tax ranges from 3% to 17%. 

However, it is possible to reduce this substantial burden through a simple process whereby "input VAT” is used to offset "output VAT.” For instance, if a trading company or manufacturing company purchases goods (and shoulders the burden of a 17% VAT), it can qualify to use such paid-out VAT ("input VAT”) as a type of credit to offset its VAT liability when it sells goods.

Obtaining the qualification to use "input VAT” to offset "output VAT” is the key, and those companies obtaining this status are called "general taxpayers” or "general VAT taxpayers.” This status can be more freely obtained upon the establishment of a new foreign invested enterprise, provided the new company effectively manages the application process; otherwise, the opportunity to obtain such status is thereafter delayed until the enterprise’s annual sales turnover reaches a certain threshold.

As one might imagine, failure to obtain such status as early as possible could adversely impact a company’s cost structure and profits.

Besides the foundational step of obtaining "general taxpayer” status, foreign investors should consider another important factor to realizing tax savings from the Chinese VAT system, which is to effectively manage the process of obtaining and utilizing "input VAT” invoices. As mentioned, "input VAT” invoices are needed to offset "output VAT,” and these invoices are physical paper invoices printed with a special printer by specially trained and qualified employees of companies that have achieved "general taxpayer” status. 

If a company’s business partner has not obtained such "general taxpayer” status, then such physical paper "input VAT” invoices will only be available by making special application to the Chinese tax bureau and, if not obtained, the company would bear a heavier burden of VAT; therefore, it is important to screen vendors or business partners to determine their taxpayer status or ability to obtain these invoices.

If and when such paper "input VAT” invoices can actually be obtained from vendors or partners, they must then first be officially verified by Chinese tax authorities through a formal process that is usually performed electronically over the Internet but that may sometimes require an in-person petition at the Chinese tax bureau. But the intricacies of the Chinese VAT system do not cease here; Timing is also an extremely important factor in effectively utilizing "input VAT.” 

"Input VAT” must be used within 180 days of issuance, and it can obviously only be used when there is "output VAT” against which it could be credited. For companies with irregular sales cycles or that complete only a few, large transactions each year, this presents a problem. If the enterprise has established an effective compliance and monitoring system, and executives are fully briefed and aware of the company’s VAT position, then the challenge can be more easily managed. 

As a foreign investor may readily see, effective management of the VAT system so as to reduce tax exposure requires focused attention and dedicated resources. Characteristics of an effective VAT monitoring and management system for China would likely include at least the following:

  • Identity VAT compliance and efficient management as an enterprise priority.
  • Place responsibility and accountability with a senior level manager 
  • Outsource and/or hire sufficient dedicated and qualified specialists 
  • Establish processes for monitoring and reporting the VAT position to enterprise leaders
  • Create a VAT position report that is included in management financial reports
  • Monitor the effectiveness of obtaining and utilizing "input VAT” and aging balances
  • Monitor VAT balances and fluctuations or variances and identify risks 
  • Establish standards and protocols that limit the risk of adverse exposure to VAT 
  • Create a risk and crisis resolution procedure to ensure problems are timely addressed 
  • Schedule and conduct VAT audits on a regular basis
  • Stay abreast of a rapidly changing regulatory environment, including, for example, the availability of VAT refunds and exemptions, and adapt processes and policies accordingly.

Because of the complexity of the Chinese value-added tax system and rapid rate of regulatory reform, foreign investors should anticipate a sharp learning curve and on-going need for professional support. Even a well-resourced and capable internal VAT management team may need to confer with industry experts to understand the latest changes and local interpretation or to draw upon additional manpower.

This article first appeared on 


Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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