My monthly sales were under ¥100k, but I issued one special VAT invoice — did I just lose my exemption?
No. You only lost the exemption on that one invoice. From January 1, 2026, the under-¥100k/month (¥300k/quarter) threshold works as a VAT threshold: sales below it are exempt — but you may forgo the exemption on individual transactions to issue special VAT invoices, and the rest of your sales stay exempt. The special-invoice portion is taxed at the applicable levy rate; everything else is untouched.
How the threshold works now
| Tax period | Threshold (2026-01-01 – 2027-12-31) |
|---|---|
| Monthly filer | ¥100,000/month |
| Quarterly filer | ¥300,000/quarter |
| Per-transaction filer | ¥1,000 per transaction (per day if multiple) |
Stay under the threshold and your sales are exempt from VAT. The key question is what counts toward the threshold: all of the month's taxable sales are added together — including the sales for which you issued special invoices. So a ¥80,000 month where ¥20,000 went on a special invoice is still an ¥80,000 month for threshold purposes.
The one-invoice rule, precisely
- Special-invoice sales can't be exempt. Whatever you put on a special VAT invoice must be declared and taxed at the applicable levy rate (1% for most small-taxpayer sales in 2026–2027). No exceptions.
- The exemption survives on the rest. The bureau's own example: ¥80,000 in monthly sales, ¥20,000 on a special invoice for a mall customer — pay tax on the ¥20,000, the other ¥60,000 stays exempt.
- Forgoing is per transaction. You choose which sales give up the exemption. One special invoice doesn't taint the month.
- The threshold test still uses the total. If total monthly sales exceed ¥100,000, the whole month loses the exemption (special-invoice or not) — so the invoice doesn't just cost tax on itself, it also pushes you toward the cliff.
So the real trap isn't "one special invoice kills everything" — it's not tracking the running total. Issue special invoices freely under the threshold; watch the cumulative number like a hawk.
Frequently asked questions
Do I have to forgo the exemption in advance, or can I decide invoice by invoice?
Invoice by invoice. There's no advance election — each time you issue a special invoice, you've forgone the exemption for that sale. Just declare it correctly at filing time.
What if I issued the special invoice but my total still stayed under ¥100k — do I file anything special?
Yes: at filing, report the special-invoice sales as taxable (at the right levy rate) and the rest as exempt/threshold sales. Mixing them up — putting exempt sales in the taxable column or vice versa — is one of the most common filing errors and draws comparisons.
Can I issue a special invoice and still be "under the threshold" if the buyer never uses it for credit?
Irrelevant. What matters is that you issued a special invoice, not what the buyer does with it. The issuance itself makes that sale taxable.
Sources
- 财政部 税务总局公告2026年第10号 (threshold: ¥100k/month, ¥300k/quarter, 2026-01-01 to 2027-12-31)
- 国家税务总局《关于起征点标准等增值税征管事项的公告》 (per-transaction forgo of exemption)
- 国家税务总局新媒体: 1%或3%专票都可以开 (forgo mechanics)
- https://www.zlketang.com/kjsc/kjsw_detail_85953.html