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Applicability of Zero Tax Rate and Issuance of Purchase Confirmation in Overseas Outbound Transactions for Processing Purposes

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The transaction structure is as follows: based on an order from our company (B), the vendor (A) delivers materials produced for module products under a JV agreement to an overseas entity (the module company). On the export documents, the Exporter/Export Agent/Shipper is the vendor (A), the Importer/Buyer is the overseas module company, and the Notify Party is our company (B). The payment method is Telegraphic Transfer (T/T). There is a material supply contract between vendor (A) and our company (B); therefore, when paying for the export transaction, vendor (A) is the supplier and our company (B) is the recipient, a zero-rated tax invoice is issued, and our company (B) issues the Purchase Confirmation. Meanwhile, our company (B) is in a JV (agreement) relationship with affiliates, and there is no direct contract between our company (B) and the overseas module company; there is only a contract between the JV entity and the overseas module company. Questions: 1. Is it possible to apply the zero tax rate and issue a Purchase Confirmation for goods purchased from vendor (A) when our company (B) has no direct contractual relationship with the overseas processing company? 2. What is the correct contractual relationship required to apply the zero tax rate? 3. Can the contractual relationship between the JV and the overseas module processing company be recognized as a contractual relationship with our company? 4. How can transactions for which payment has already been made applying the zero tax rate be corrected? 5. What type of trade transaction structure exists between vendor (A) and our company (B)?

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