Why can't the freight forwarding service charge be deducted from the VAT input tax?

According to the Announcement on Value-added Tax in International Freight Forwarding Business (Announcement No.42 of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC), No.20 14), since September 20 1 41day, taxpayers have indirectly handled the international transportation of goods and the entry and exit of means of transport engaged in international transportation for their customers through other agents, as well as contacted and arranged pilotage, berthing, loading and unloading, etc.

The purchase of duty-free goods has obtained the VAT deduction certificate (except for the purchase of duty-free grain from state-owned grain enterprises), and the input tax is not allowed to be deducted. Therefore, the import tax can't be deducted from the freight invoices obtained by export enterprises (including production enterprises and foreign trade enterprises).

According to the Provisional Regulations on Value-added Tax and its detailed rules for implementation, the geographical scope of application of value-added tax is within the territory of People's Republic of China (PRC). In view of the fact that the imported goods enterprises have obtained transport invoice, the transportation services are transported overseas, which does not belong to providing taxable services in China. Therefore, transport invoice obtained abroad cannot be deducted from the VAT input.

Before September 1 day, 2004, the agency sea freight obtained by foreign trade export enterprises shall not be deducted from the input tax. Document basis: Reply of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC) on Domestic Freight Deduction of Export Goods (Guo [1997] No.441): Foreign trade enterprises implement export tax rebate management measures for their export goods, which is a way of VAT exemption and belongs to VAT exempt goods. Therefore, the transportation expenses incurred by its export goods shall not be deducted when calculating the input tax.

Goods transportation belongs to the scope of "VAT reform", and general taxpayers uniformly use special invoices for goods transportation services. For coastal transportation (that is, maritime transportation between coastal ports in China), in accordance with the policy of "reform of the camp", general taxpayers can issue special invoices for freight. If the payer meets other conditions, the sea freight input tax can be deducted.

If the sea freight is generated by international freight, can I issue a special invoice for freight? In this regard, in accordance with the provisions of the second paragraph of Article 21 of the Provisional Regulations on Value-added Tax, sales of goods or taxable services are tax-free, and special invoices for value-added tax may not be issued. In addition, it can be inferred from the announcement of State Taxation Administration of The People's Republic of China on the Administrative Measures for Exemption, Refund and Supplement of Taxable Services with Zero VAT Rate in the Pilot Area of Changing Business Tax to VAT (Provisional) that international freight should use ordinary invoices instead of special invoices for freight, and the drawee cannot deduct the input tax on sea freight.

At the same time, the Notice of State Taxation Administration of The People's Republic of China City, People's Republic of China (PRC) on Amending the Provisions on the Use of Special VAT Invoices (Guo Shui Fa [2006]156) stipulates that special invoices shall not be issued for the sale of duty-free goods, unless otherwise stipulated by laws and regulations of People's Republic of China (PRC) and State Taxation Administration of The People's Republic of China. Although international transportation is a "service" here, it is different from goods, but the principle of value-added tax should be the same.

To sum up, the sea freight generated by international cargo transportation cannot be deducted from the VAT input tax; At the same time, it is considered that because China Shipping Company provides international transportation services to the outside world and the tax rate is zero, ordinary invoices should be used instead of special VAT invoices.