Prepare evidence for reviewing missing purchase invoices in mainland China
Link supplier, order, delivery and payment evidence when purchase invoices are missing, and separate accounting, income tax and VAT decisions.
Goods have arrived and the supplier has been paid, but the purchase invoice is still missing. An ecommerce business should neither treat the entire payment as a current expense nor assume that a payment screenshot replaces an invoice. Establish what was bought, who supplied it, when it was received and how it is used; then assess accounting, enterprise income tax deductions and input VAT separately.
This guide addresses mainland China ecommerce companies and their finance teams, focusing on domestic purchases. Confirm the applicable accounting framework, enterprise income tax assessment method, VAT method and transaction period first. Individual business operators' personal income tax treatment and overseas purchases require their own analysis.
Connect five sets of evidence for each purchase
Use an identifiable purchase or purchase batch as the unit of review. Keep the allocation when several invoices cover one order, or one invoice covers several deliveries. Equal amounts alone do not prove that two records belong together.
| Review area | Evidence and facts to assemble | Question to resolve |
|---|---|---|
| Supplier and buyer | Supplier identity, contracting parties, purchasing company and collection arrangements | Who sold to whom, and was an intermediary involved? |
| Purchase terms | Order, contract, item specifications, quantity, price and amendments | What was purchased, and what does the price cover? |
| Delivery | Shipping, receipt, warehouse, acceptance and return records | What actually arrived, and what was returned? |
| Settlement | Bank or platform payments, supplier statements, refunds and unpaid balances | Which payment covers which purchase, including advances or combined payments? |
| Invoice and period | Invoices received, missing items, follow-up records and existing accounting entries | Is the gap a missing invoice, partial coverage, a defective document or a timing difference? |
For example, a transfer might combine an advance for a new order with the balance due on an earlier delivery. Do not classify all of it as this month's goods purchase. Establish the links first, then have the finance team assess goods received, goods in transit, returns and advances separately. This illustrates a review sequence, not an accounting conclusion for a particular company.
Make three separate decisions
Accounting follows the transaction and the applicable framework. Preserve evidence of actual receipts, payments and liabilities while the invoice issue is unresolved. Whether a purchase is inventory, an advance, another asset or an expense—and which period it belongs to—depends on the facts, use and existing records. A missing invoice should not make the underlying activity disappear; receiving an invoice does not make every purchase an immediate expense.
Enterprise income tax deductions require the relevant expenditure and evidence conditions. State Taxation Administration Announcement No. 28 of 2018 addresses the authenticity, legality and relevance of deduction evidence and supporting material. For a domestic VAT-taxable purchase from a tax-registered VAT taxpayer, Article 9 generally requires an invoice. Both the real transaction and the documentary requirements need review.
Input VAT depends on its own rules. Check the VAT calculation method, qualifying deduction document and purchase use. Articles 16 and 22 of the VAT Law, effective from 1 January 2026, address deduction documents and excluded input tax. A bank record, contract or internal explanation does not automatically become a valid VAT deduction document. An enterprise income tax deduction does not establish VAT deductibility.
Choose the next step according to the reason
The supplier is operating normally but has not issued the invoice. Reconcile the order, receipt, payment and missing coverage, then request the correct document from the actual counterparty. Record the owner and follow-up date. Article 13 of Announcement No. 28 specifies a deadline tied to the end of the relevant annual enterprise income tax reconciliation period for qualifying supplementation or replacement. Do not leave the request indefinitely pending.
A specific event, such as supplier deregistration, prevents replacement. Obtain objective evidence of that event; a note saying the supplier did not reply is not enough. Article 14 has a defined alternative evidence route. Proof of why replacement is impossible, the contract or agreement, and non-cash payment evidence are mandatory elements, alongside relevant delivery, inventory and accounting support. An ordinary refusal to issue an invoice does not automatically qualify.
The supplier is an individual or an entity legally exempt from tax registration. Do not infer that a receipt is sufficient simply because the seller is an individual. Check Article 9's conditions, the small-scale incidental business criterion applicable to the period, and the required receipt information. Keep any required personal identification information in controlled company records, not public comments or discussion threads.
Deliver an evidence gap list with deadlines
A useful follow-up sheet identifies the purchase batch, company, period, established facts, missing evidence, owner and deadline. Track the three review outcomes separately—for example, accounting reviewed, income tax evidence pending, and VAT treatment unconfirmed. A single “completed” label can hide an unresolved tax question.
After the annual reconciliation deadline, establish whether the expenditure was previously deducted, what evidence has since become available and whether the tax authority has issued a notice. The Shanghai tax authority's 2026 enterprise income tax Q&A explains supplementation and conditional prior-year treatment. A late invoice does not automatically belong in the current year's deduction. The responsible finance professional should determine any correction under the relevant provisions; an invoice for an unrelated transaction is not a substitute.
The official texts were checked on 31 October 2026. Start with one supplier and one purchase period, preserve the original records, and identify discrepancies and missing evidence. The ecommerce fee evidence guide and tax consultation example show related ways of working. To discuss CaiGeek software or separately agreed finance services, use the official contact page. These examples do not mean your company's review has already been completed; actual treatment requires its facts and professional review.
Written with AI assistance. Examples illustrate analysis methods; apply them using business records and relevant conditions.
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