A Chinese client wants a fapiao: what do you do if you have no company in China?

Your first Chinese client is ready to sign, then their finance team asks for a fapiao. Most guides explain what a fapiao is. Few tell a company outside China what to do next.

A missing fapiao doesn’t have to end the deal. This guide is part of the legal basics of a website in China. It’s general information, not tax advice.

What is a fapiao?

A fapiao is China’s official tax invoice. It’s issued through the Chinese tax system, and it’s far more than a bill. Chinese companies use it to support their VAT and expense records.²

Since December 1, 2024, the fully digitalized e-fapiao has applied nationwide, with the same legal force as paper.¹⁵

It’s issued on a free national platform run by the tax authorities.¹⁵ Each one carries a 20-digit number, according to AWS China’s guide.¹⁶

	Special VAT fapiao	General VAT fapiao
Who issues it	General taxpayers only 2	General taxpayers and small-scale businesses 2
Buyer can deduct the VAT	Yes 25	No 2
Language	Chinese, with an optional foreign language 1	Same 1

Can a foreign company issue a fapiao?

No, not without a Chinese entity. Stripe states that a fapiao can only be issued by an entity registered for VAT in China.² Invoice Data Extraction, a vendor, says the same of a Hong Kong invoice, however detailed it is.³

Stripe adds that a foreign business could use an agent acting on its behalf, but it doesn’t explain the arrangement.² Don’t treat that as a route until an adviser has confirmed it.

So your client isn’t asking for a better version of your invoice. It’s asking for a document your company has no way of producing.

Under the 2023 Invoice Measures, the party receiving the payment issues the invoice to the party paying, with special cases where the payer issues it.¹

Whether you can sell to China at all without a local company is a separate question, covered in doing this without a Chinese company.

What can your client use instead?

Your client has a legal route that doesn’t depend on a fapiao. This is the point to make to its finance team, because the rules for purchases from abroad differ from the domestic ones.

What the client needs	What supports it	Source
Deducting the expense for corporate income tax	Your invoice or a receipt of the same nature, plus the related tax payment documents	Announcement No. 28 of 2018, Art. 11 7
Deducting VAT on your service	The tax payment certificate showing the VAT, plus the written contract, proof of payment and your statement or invoice	VAT Regulations, Arts. 11 and 12 5; Announcement No. 13 of 2026 21
Accepting a document from abroad if the tax authority doubts it	Possibly a confirmation from a foreign notary or accountant, then the authority’s approval	Invoice Measures, Art. 32 1

The VAT route isn’t new. The old VAT regulations allowed it,²² and the regulations in force since January 1, 2026 keep it: they name the tax payment certificate as a deduction document, and cover VAT shown on it for services bought from a foreign seller.⁵

A January 2026 announcement sets the paperwork. A general taxpayer deducting on that certificate must hold a written contract, proof of payment and the foreign seller’s statement or invoice.²¹

So your invoice isn’t a fapiao, but it can be one of the documents the deduction rests on.

That doesn’t cover every client or every purchase. KPMG noted in January 2026 that more implementing rules were coming,²⁰ so its adviser has the last word.

What tax comes out of your invoice?

Generally 6% VAT, and possibly income tax too. Your client handles both.

Chinese law makes the buyer the withholding agent when a foreign seller makes a taxable sale in China, unless a local representative has been appointed under State Council rules.⁴

VAT

The VAT Law sets 6% for services outside the categories it lists at other rates.⁴ A service counts as consumed in China when a foreign seller sells it to a buyer in China.⁵

DLA Piper gives the example of a foreign consulting firm advising a Chinese company without ever entering China. That service counts as consumed in China, and the payer withholds.⁶

There’s one exception: services consumed on site abroad. DLA Piper’s examples are catering, tourism and exhibitions.⁶

Corporate income tax

This part is unsettled, and the sources don’t line up.

• The EU SME Centre says services for a China-based client are treated as Chinese income, generally taxed at 10%.⁸
• The income tax regulations place service income where the service is performed, with a reduced 10% rate for certain non-resident income.⁹
• A tax treaty can change the result. Horizons Corporate Advisory notes that a lower treaty rate applies where there is one.¹⁰

So a client may withhold income tax even on work you did at home. Ask why it’s doing so, and check your case with a tax adviser.

Surcharges

The EU SME Centre still lists surcharges of 0.72%, on a page whose resources date from 2017.⁸

Since September 1, 2021, VAT paid on services bought from abroad has been outside the base of the urban construction tax, and the education surcharges were aligned with it.¹¹

We don’t give a combined rate here, because it depends on your service, your country and your treaty.

How much will you actually receive?

That depends on what your contract says about tax. The EU SME Centre advises stating that payment is net of taxes, or raising your price in advance.⁸

Harris Sliwoski warned in 2017 that if the documents are silent, the Chinese side falls back on the rule that puts the tax on the foreign party.¹⁴

China’s VAT is calculated on the price excluding VAT.⁴ The same fee can therefore produce two different results.

Currency exchange and bank fees aren’t included. Harris Sliwoski also wrote in 2017 that deductions at payment varied by bank and region, from 5% to 40% in the cases it saw,¹⁴ so test a first payment before you rely on a figure.

DLA Piper makes the same point about clarifying withholding and filing duties in contracts.⁶ The EU SME Centre adds that the amount withheld generally can’t be recovered in China, though it may be deductible at home.⁸

Payment dates matter too. The VAT duty arises when payment is received, when a payment claim is obtained, or when an invoice is issued first.⁴ The regulations read that claim as the payment date in a written contract, or completion if there’s none.⁵ The withholding duty arises the same day.⁴

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What to do when a client asks for a fapiao

Answer quickly and calmly. A clear reply reassures a finance team more than a long explanation does.

1. Ask what the fapiao is for. Is it for the expense deduction, the VAT credit, or internal policy? Each has a different answer.
2. Confirm who is paying. The rules above concern a buyer in China, so check which entity signs and pays.
3. Explain what you can issue. State that you’re a foreign company with no Chinese VAT registration, and offer a signed invoice, the contract and a statement of account if asked.
4. Point to the rules. Give finance the references in the table above, so their adviser can check them.
5. Agree the tax before signing. Settle who bears each tax, and write it into the contract.
6. Check the USD 50,000 filing. Above that amount per payment, your client files with its tax bureau, once per contract, before the first payment.¹²¹³
7. Ask for the proof. Horizons says the Chinese payer must give you notice of the tax withheld and paid, which may support a credit at home.¹⁰

1. 1Contract states who bears tax
2. 2Your signed invoice
3. 3Client files if above USD 50,000 and withholds
4. 4Client pays tax and gets certificate
5. 5You receive payment and a copy of the proof

The filing is your client’s job, but it can delay your payment. It produces a filing number and a verification code for the bank.¹³ Tax found unpaid can then be pursued by the authorities.¹²

That’s also why a client may seem cautious. A 2017 China Briefing article says that if a client fails to withhold, the tax bureau pursues the client.¹⁹ It adds that enforcement isn’t uniform.¹⁹

What should your invoice include?

We found no official template for a foreign seller’s invoice to a Chinese client. The 2026 announcement names the document but sets no format,²¹ so what follows is a suggestion, not a legal requirement.

The one published recommendation we read is Harris Sliwoski’s, from 2017: a written, signed and chopped invoice for every payment, stating that payment is net of taxes and fees.¹⁴

These details make the reviewer’s work easier:

• Your full legal name, address and registration number
• The client’s exact registered name, in Chinese as well as English
• The client’s tax ID, if it gives you one
• The contract reference and date
• A plain description of the service and the period covered
• The amount, the currency and your bank details
• A line saying that this is not a Chinese fapiao

A company stamp isn’t common in every country. If your client expects one, it’s a small thing to agree on before the first invoice.

What if the client insists on a real fapiao?

Then the fapiao has to come from a Chinese entity that genuinely makes the sale.

Route	Who issues the fapiao	What it takes
Stay cross-border	Nobody, your invoice stands	The client’s finance team accepts the route above
Sell through a local reseller 18	The reseller, for its own sale	A real contract between reseller and client, and a margin for the reseller
Open your own entity	Your entity	Registration, tax setup and fapiao setup, over several months 17

The reseller route is well documented for products. Harris Sliwoski describes an independent distributor as the most practical path for many small and midsize companies.¹⁸ For services, check it with an adviser first.

For the third route, see whether you need a WFOE. It’s a large step to take for one invoice.

Above RMB 10,000, the fine runs from RMB 50,000 to RMB 500,000, on top of confiscated gains, and criminal liability can apply.¹

The risk isn’t only yours. An invoice that breaks the rules can’t serve as an expense voucher, and anyone can refuse it.¹

A Chinese entity with a real role in the deal is a different matter from a seller of paper. Ask a local adviser which one you’re looking at.

For the bigger picture, see how to sell to Chinese clients without being in China.

The bottom line

If you have no Chinese entity, you can’t issue a fapiao, so don’t try to imitate one. Offer a signed invoice, point your client to the rules on purchases from abroad, and settle who bears the tax before you sign.

Have a tax adviser check the first contract. Consumer payments are a separate matter, covered in accepting Alipay and WeChat Pay.

How Index in China can help

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