What is a fapiao?
A fapiao (发票) is the payment voucher issued through China’s tax system, defined by Article 3 of the Invoice Management Measures. A special VAT fapiao lets a general taxpayer credit input VAT; a general fapiao does not. It is not the same as a commercial invoice, and since December 2024 the standard form is digital.
The fapiao trips up nearly every foreign business operating in China, and the confusion is almost always the same one: treating it as the Chinese word for invoice. It is not a translation of anything. It is a state-supervised voucher, and the document you would call an invoice at home is a private piece of paper that has no standing in the Chinese tax system at all.
What a fapiao actually is
A receipt-and-payment voucher issued or received in the course of buying and selling goods, providing or receiving services, or other business activity (Invoice Management Measures, Article 3).1 That definition is doing more work than it looks. The obligation runs between the two parties to a transaction: the payee issues to the payer (Article 18), and the payer must obtain one when it pays (Article 19). A non-compliant invoice cannot be used as a reimbursement voucher, and anyone has the right to refuse it (Article 20).1
Fapiao and commercial invoice are different documents
| Document | Issued by | What it is for |
|---|---|---|
| Fapiao(发票) | The seller, through the tax authority’s system, against a quota the authority grants | Chinese tax: expense deduction, VAT credit, and evidence the transaction was declared |
| Commercial invoice | The seller, on its own paper, in whatever form it likes | International trade: customs clearance, payment, and the shipping document set |
The difference is who stands behind the document. A commercial invoice is the seller’s own assertion. A fapiao is issued through a state system that has already recorded the transaction, which is why it can do things a private document cannot, and why a seller who does not want the transaction recorded does not want to issue one.
Special VAT fapiao or general fapiao?
This is the distinction that decides money. Under the VAT Law, input tax is credited against output tax only on a credit voucher prescribed by law, administrative regulation or the State Council (Article 16),2 and the list of those vouchers sits in Article 11 of the implementing regulations.3 A special VAT fapiao is on that list. A general fapiao is not.
| Form | What it supports | Who can use it |
|---|---|---|
| Special VAT fapiao(增值税专用发票) | An input VAT credit, and the expense deduction | A general taxpayer. This is the one a Chinese business normally wants |
| General fapiao(增值税普通发票) | The expense deduction only. No input VAT credit | Anyone, but it leaves the VAT with you |
Which of the two a supplier can issue depends on what it is registered as. The line between a small-scale taxpayer and a general taxpayer is annual VAT-taxable sales of RMB 5 million, and since 1 January 2026 that figure is written into the VAT Law itself rather than left to a circular (Article 9).2 Ask a new supplier which it is before you agree a price, because it determines whether the VAT in that price is recoverable by you or simply a cost.
The digital fapiao is now the standard form
Since 1 December 2024 the fully digitalised electronic fapiao (数电发票) has been in national use.4 It is a species of electronic invoice under the Invoice Management Measures and it has the same legal effect as paper, which the Measures state in general terms at Article 3 and the implementing rules put beyond argument: no unit or individual may refuse to accept one.1 Four practical consequences follow, and they overturn most of what a foreign manager was told on arrival.
- It is a single record, not a book of copies. The old question of which copy you keep has gone.
- It carries no chop. Article 21 requires the invoice chop only on a paper fapiao, so a digital fapiao arriving as a file with no red stamp is not defective, and a supplier pasting a chop image onto one is doing something no rule asks for.
- There is no hardware to buy and no invoice stock to collect. The tax authority runs a free national platform and grants each taxpayer a total invoicing quota, adjusted dynamically according to risk, credit rating and actual operations, with issuance authenticated against a real person.
- Receiving it is not the last step. A recipient intending to claim the input VAT credit must confirm the invoice’s use through its tax digital account. Holding the document is not enough.
Does the fapiao need your tax number?
Yes, where the buyer is an enterprise. Since 1 July 2017 a buyer that is an enterprise asking for a general VAT fapiao must give the seller its taxpayer identification number or unified social credit code, and the seller must enter it in the buyer’s tax number field; an invoice that does not comply may not be used as a tax voucher.5 That is the rule behind a piece of advice that otherwise sounds fussy: the fapiao must carry the registered Chinese name and the tax number, not a trading name. A fapiao made out to the wrong entity is not usable by either of them.
What happens if there is no fapiao?
Normally the expense is not deductible, but the flat version of that rule is wrong and it misleads the readers of this page most often. The governing instrument is the Measures for Pre-Tax Deduction Vouchers.6 Where the expense is a domestic VAT-taxable item bought from a registered taxpayer, the fapiao is the deduction voucher (Article 9). Four situations sit outside that.
| Situation | What you deduct on instead |
|---|---|
| You bought from outside China | The foreign supplier’s own invoice, or a receipt of the nature of an invoice, plus the relevant tax payment vouchers (Article 11). No fapiao exists for the transaction and none is required |
| The item is not VAT-taxable | Other external vouchers where the counterparty is an organisation, or internal vouchers where it is an individual (Article 10). Payroll and social insurance were never fapiao questions |
| A small, occasional purchase from an individual | An invoice issued by the tax authority on the seller’s behalf, or a receipt plus internal vouchers, where the seller is below the VAT threshold or need not register for tax (Article 9) |
| The supplier has been deregistered or struck off | Evidence of why no invoice can be obtained, the contract, and a non-cash payment record, all three being mandatory, supported by transport and warehouse records and the accounting entries (Article 14) |
There are also two repair windows worth knowing before a year closes. A missing or non-compliant invoice can be reissued up to the end of the annual corporate income tax reconciliation period, and where the tax authority raises it later the company has 60 days to obtain a replacement or produce the evidence above. An expense that went undeducted because no invoice was obtained can be carried back to the year it arose once a compliant invoice appears, for up to five years.6 None of that makes a missing fapiao harmless, but it does mean a missing one is a problem to work rather than a loss to book. The annual reconciliation is when it surfaces.
Why a seller sometimes resists, and what the rules say about it
Because issuing a fapiao declares the revenue. A quoted price is sometimes “without fapiao”, with a higher price if one is required, and the difference is tax that would otherwise not be paid. Accepting the cheaper option leaves your own entity with an expense it cannot deduct and no documentary support for it, so the discount is usually smaller than it looks.
The rules are not neutral on this. Failing to issue an invoice when one should be issued is an offence: the tax authority may order correction, impose a fine of up to RMB 10,000 and confiscate any illegal gains (Article 33(1)). Substituting some other voucher for a fapiao is separately prohibited (Article 23(5)), which is the answer to a supplier offering a receipt instead.1 Settle the question when you agree the price, not when you pay.
Does a company outside China need a fapiao?
No. The Invoice Management Measures are territorial: they bind units and individuals printing, drawing, issuing, obtaining, keeping or cancelling invoices within China (Article 2).1 A company with no establishment and no taxable activity in China has nothing it is obliged to issue, and no authority from which it could draw invoice stock or obtain a platform quota. From the other side of the same transaction, a Chinese subsidiary paying an overseas affiliate deducts on the foreign invoice under Article 11 above.6
One caution, because the two questions get merged. Being outside the fapiao regime is not the same as having no Chinese tax exposure. A foreign supplier of services to a Chinese customer can still fall inside Chinese VAT, in which case the Chinese payer withholds, and the payer’s credit voucher is then the tax payment certificate rather than a fapiao. The absence of a fapiao removes neither withholding VAT nor withholding income tax.
How long do you have to keep them?
Ten years in practice. Two periods are often quoted and they answer different questions. An issuer must keep the counterfoils of invoices it has issued for five years (Invoice Management Measures, Article 28).1 Everything a company holds as a tax record, including the fapiao it has received, falls under Article 29 of the implementing rules of the Tax Collection and Administration Law, which requires books, accounting vouchers, statements, tax payment certificates, invoices and export documents to be kept for ten years unless a law or administrative regulation says otherwise.7 For a foreign-invested company, plan on ten. That digital fapiao can be downloaded again from the tax digital account is a convenience, not a substitute for the duty.
We are not an accounting firm and do not keep books, file tax returns or advise on VAT treatment. What is useful to know as a manager is which document does which job, that the special and general forms are not interchangeable, and that the question is worth raising early enough to be priced rather than argued about.
Want this done rather than explained? Business Agency & Filing Support From US$180, 2–10 working days. See the service Sources
- Measures for the Administration of Invoices of the PRC, as revised by State Council Order No. 764 (20 July 2023): Articles 2, 3, 18, 19, 20, 21, 23, 28 and 33, with the Implementing Rules (STA Order No. 56, in force 1 March 2024), Article 3 (State Taxation Administration policy library, retrieved 21 September 2026)
- Value-Added Tax Law of the PRC (Presidential Order No. 41), in force 1 January 2026 and repealing the Provisional Regulations: Articles 9, 16, 34 and 38 (State Taxation Administration policy library, retrieved 21 September 2026)
- Implementing Regulations of the VAT Law of the PRC (State Council Order No. 826, signed 25 December 2025), in force 1 January 2026: Articles 6, 7 and 11, the list of input VAT credit vouchers (State Taxation Administration policy library, retrieved 21 September 2026)
- State Taxation Administration Announcement 2024 No. 11 on the nationwide rollout of the fully digitalised electronic invoice, in force 1 December 2024: Articles 1, 2, 5, 6, 7 and 10 (retrieved 21 September 2026)
- State Taxation Administration Announcement 2017 No. 16 on the issuance of VAT invoices, in force 1 July 2017: Article 1, the buyer’s taxpayer number on a general VAT fapiao (retrieved 21 September 2026)
- Measures for the Administration of Pre-Tax Deduction Vouchers for Enterprise Income Tax (STA Announcement 2018 No. 28), in force 1 July 2018: Articles 9, 10, 11, 13, 14, 15 and 17 (State Council Gazette, retrieved 21 September 2026)
- Implementing Rules of the Tax Collection and Administration Law of the PRC (State Council Order No. 362), in force 15 October 2002: Article 29, ten-year retention of books, vouchers, invoices and export documents (State Taxation Administration policy library, retrieved 21 September 2026)
All sources checked 21 September 2026. This page is general information, not legal, tax or customs advice. Requirements vary by product, market and circumstance. Confirm your own position before acting.
