Three sentences

  • 01 A pass is not proof A passed invoice check proves only that the data on its face is currently verifiable — not that the trade is genuine, that title sits with the seller, or that the input tax will ultimately be creditable.
  • 02 Five chains, one story A00 ingot purchases need the contract, cargo, title, funds and invoice chains checked together, with payment tied to title transfer, acceptance and invoice status.
  • 03 Any red flag, stop If a third party issues the invoice, payment is requested to a personal account, the warehouse refuses to confirm title, the goods and the invoice diverge, or a “premium to buy an invoice” is proposed, pause the deal at once.

Compliance note: this article is for internal transaction control and does not replace an opinion from the competent tax authority, a certified accountant or a lawyer on a specific matter. Where tax law, the digital invoice system or local practice change, the latest rules govern.

I. A 1.5% discount to the published spot price — why the invoice still needs scrutiny

A price below the published spot price is not, on its own, unlawful. Regional spreads, brand differences, storage cost, payment terms, cash-flow pressure and bulk volume can all produce a legitimate discount. What genuinely needs checking is whether the discount can be explained by ordinary business logic, and whether the seller earned its invoicing capacity through real purchases, real title and real tax payment.

The figures below are a risk illustration only and do not represent a live market quote:

Line itemExample basisResult
Published benchmark (tax incl.)CNY 24,080/tonne
Purchase price24,080 × 98.5%CNY 23,718.80/tonne
Volume100 tonnes
Total incl. tax23,718.80 × 100CNY 2,371,880
Discount24,080 × 1.5% × 100CNY 36,120
Corresponding input tax2,371,880 × 13 ÷ 113≈ CNY 272,871

In this example, if the invoice cannot be credited and an input-tax reversal is required, the potential tax exposure is roughly 7.6 times the discount received — on top of possible back-tax, late-payment surcharges, legal fees and recovery costs. A purchase discount cannot cover the risk of a failed invoice, and a low price is no substitute for title and tax due diligence.

II. Three things that must not be conflated

ItemWhat it provesWhat it does not prove alone
Invoice check passedThe invoice number, issuer and amount exist and the current status is queryableNot proof on its own that the trade is real, the goods exist, or the seller holds title
Goods seen at the warehouseGoods matching quantity or appearance are physically presentNot proof on its own that the goods belong to the seller, are unpledged, or have not been sold twice
Good-faith acquisitionWhere conditions are met, may bear on how the buyer's own culpability is assessedDoes not automatically preserve the right to credit input tax; tax already credited may still be clawed back

The most common mistake is treating one piece of evidence as the whole case: an invoice-check screenshot standing in for transaction verification, a loading photo standing in for proof of title, or a contract indemnity clause standing in for pre-payment control. The right approach is to make different pieces of evidence corroborate one another.

III. The minimum standard: five chains, one consistent story

  • 1 Contract chain The contract, order, quotation, settlement sheet and statement must all refer to the same lot. Parties, product name, specification, quantity, pricing basis, tax rate, delivery point and risk-transfer milestone must not contradict each other.
  • 2 Cargo chain Quality certificates, furnace/ingot-number photos, bin location, goods-in and goods-out notes, weighbridge tickets, vehicle details and sign-off records should correspond continuously. For A00 deals, state “aluminium ingot / Al99.70 (A00)” in the contract and invoice rather than a generic “metal material” description that can mask a different grade.
  • 3 Title chain The seller should explain how it obtained title and provide verifiable upstream purchase, payment or transfer records. A third-party warehouse should confirm directly to the buyer: who the goods belong to, whether they are pledged or frozen, when transfer occurs, and who controls release afterwards.
  • 4 Funds chain In principle, payment goes only to the seller's own corporate bank account under the same name as the contract counterparty. A personal account, an employee's account, a related-company account or an intermediary account should never be accepted on the seller's word alone. Where an assignment or entrusted collection is genuinely needed, it requires proper documentation, tripartite confirmation and specific sign-off from finance and legal.
  • 5 Invoice chain In principle the invoice issuer must match the contract seller. Buyer, seller, product name, specification, unit, quantity, unit price, amount, tax rate and tax on the invoice should match the contract, the settlement and the actual goods; also confirm the invoice has entered the buyer's tax digital account in normal status, and complete internal purpose-confirmation and booking.

IV. Before the deal: vetting the supplier and its invoicing capacity

For a new counterparty, or one offering a noticeably better price, complete at least the following checks:

  1. Business licence, unified social credit code, legal representative, registered address and date of incorporation;
  2. General-taxpayer registration, tax-credit rating, and whether it is lawfully able to issue a goods-type VAT special invoice;
  3. Whether the actual place of business, staff, assets and trading history match the scale of this deal;
  4. Upstream source of the ingots, producer, brand, furnace/lot number, warehouse-in date and how the seller acquired them;
  5. Whether the name on the corporate bank account exactly matches the contract seller;
  6. Whether there is an abnormal-operation flag, a major tax-violation record, a default listing, or frequent changes of legal representative or address;
  7. Whether the seller can explain why its price is below the local like-for-like spot price including tax.

Five questions to get answered

  1. Who produced this lot, what is the brand, the furnace number and the original warehouse-in date?
  2. Through what transaction did the seller obtain title, and can it produce verifiable upstream purchase and payment evidence?
  3. Is the warehouse willing to confirm title, stock and unpledged status directly to the buyer?
  4. Does the discount come from a regional spread, a brand gap, storage cost, payment terms, or a cash-flow need?
  5. Who issues the invoice and when, what are the tax rate and product name, and who bears the loss if it turns out to be an abnormal voucher?

If the only answer a seller can give is “we have the goods, we can invoice, the price is good” — while refusing to explain the source of title, the source of input tax, or the warehouse — the risk has not actually been explained away.

V. At signing: put the controls into the contract

Control pointRecommended wordingVague wording to avoid
Pricing basisState the price publisher, region, date, average price, discount and whether tax is included“Discounted off the published price”
Cargo descriptionA00 / Al99.70 ingot, stating brand, furnace/lot number, quantity and applicable standard“Aluminium product” or “metal material”
Delivery and title transferSpecify warehouse transfer, release conditions and the risk-transfer milestoneJust “delivery at warehouse”
Invoicing obligationIssue a lawful, valid digital VAT special invoice for the full settlement amountJust “provide an invoice”
PaymentPay only to the seller's own corporate account under the same nameLetting the seller nominate an account at any time
Remedy for an abnormal invoiceSet a re-issue deadline, tax-loss make-good, late-payment surcharge and recovery costsJust “the seller will handle it”
Credit-note constraintNo credit note without a genuine return, allowance or invoicing error as the basisNo provision on credit notes at all

The contract can carry this core logic: the seller warrants that the trade is genuine, the goods have a lawful source and it holds full disposal rights; where the seller's own fault causes the invoice to be falsely issued, out of control, abnormal, non-creditable, cancelled by a red-letter note, or requires an input-tax reversal, the seller must re-issue a lawful valid invoice within a set period and compensate the buyer's actual loss. The buyer is entitled to withhold the balance payment, set off against a retention/deposit, and require the seller's cooperation with upstream purchase, payment, warehousing, transport and tax records.

A contract clause provides grounds for recourse — it does not replace the buyer's duty to verify the trade before paying.

VI. Delivery: warehouse title confirmation matters more than seeing the goods

In warehouse spot deals such as those at Gongyi, procurement staff should contact the warehouse independently rather than relying only on a contact the seller supplies. Before arrival, send the warehouse the brand, furnace number, bin location, weight, piece count and planned transfer time for a pre-check.

On site, complete at least the following:

  1. Check the ingot brand mark, furnace or lot number, packaging, appearance and quality certificate;
  2. Count vehicle by vehicle or stack by stack, log the bin location and quantity, and pull a sample representative of the lot;
  3. Obtain the weighbridge ticket, goods-out note, and vehicle and driver details;
  4. Record continuous video with a visible time and location, covering the warehouse signage, the bin, the goods and the loading process;
  5. Get written confirmation from the warehouse of the original title holder, unpledged status, the transfer time, and how release is controlled after transfer.

If the warehouse will only confirm “we've seen the goods” but refuses to confirm who they belong to or whether they are pledged, that is not a basis for paying.

VII. Receiving the invoice: a line-by-line digital-invoice checklist

The buyer should not simply accept the PDF, image or QR code the seller sends. Finance should work from the tax digital account and the official verification result, and complete the following checks invoice by invoice:

  1. The invoice has entered the company's own tax digital account;
  2. The seller's name and unified social credit code match the contract seller;
  3. The buyer's name and unified social credit code are accurate;
  4. The product name genuinely reflects the goods, and specification, quantity and unit price match the settlement sheet;
  5. The tax-exclusive amount, tax rate, tax amount and total incl. tax are calculated correctly;
  6. The invoice date does not obviously conflict with the tax point, delivery or settlement milestone;
  7. The invoice status is normal, with no void, credit-note or abnormal flag;
  8. The corresponding goods have completed acceptance, title confirmation or delivery;
  9. Purpose has been confirmed, booking is complete internally, and the XML, PDF and system verification record are retained.

The following mismatches cannot simply be talked around: buyer or seller tax ID wrong, quantity or amount not matching settlement, non-standard aluminium invoiced as A00, an invoice issuer different from the contract seller, or a third party demanding payment after the invoice has entered the digital account. Suspend crediting and payment, establish the cause, and then either re-issue lawfully via credit note or terminate the deal.

VIII. Payment: hold the balance until the invoice has cleared

For a first-time or medium-risk supplier, an internal control such as “88% on title transfer, 12% balance once the full invoice has cleared and been booked” is one workable structure:

MilestoneSuggested shareCondition to pay
Unsecured advance0% in principleIn principle, no unsecured advance to the seller on a first order
Title-transfer payment88%Warehouse title confirmation and transfer, on-site acceptance, weighing and settlement complete, corporate account verified
Invoice-clearance balance12%The full digital special invoice has entered the buyer's tax digital account in normal status and content, with internal verification complete
Risk retention3%–5% for higher-risk casesPaid after an agreed observation period with no credit note, abnormal voucher or other tax risk

88%/12% is not a ratio mandated by tax law — it is an example first-order control. For an established supplier the ratio can flex with credit terms, warehouse-receipt control and guarantees, but title, corporate-account and invoice-authenticity checks cannot be dropped.

IX. Notified of an abnormal voucher: what to do in the first 24 hours

The sequence is: stop the bleeding and preserve evidence first, then handle the tax treatment and contract recourse.

Immediate actions

  1. Log the notice time, invoice number, amount, tax amount, supplier and the corresponding contract;
  2. Suspend unpaid balances, new orders, unlifted goods and any pending payment approval for that supplier;
  3. Do not credit tax not yet credited; where it has already been credited, finance handles input-tax reversal or a verification request as the competent tax authority requires;
  4. Send the seller written notice requiring an explanation, supporting documents and a re-issued lawful invoice within a set period;
  5. Build the evidence package within 24 hours;
  6. Have legal assess offsetting against the retention, a loss claim, guarantee recourse or a preservation order.

The evidence package should include at least

  1. The contract, order, quotation, settlement sheet, statement and business correspondence;
  2. Warehouse confirmations, the warehouse receipt, goods-in/out notes, weighbridge tickets, transport documents, vehicle and sign-off records;
  3. Quality certificates, test reports, furnace/ingot-number photos and sampling records;
  4. Corporate payment receipts, payment approvals, refund and retention-deposit records;
  5. The invoice XML/PDF, digital-account records, verification screenshots, purpose confirmation and credit-note records;
  6. Corporate registry, tax-credit rating, business-premises, supplier-admission and internal approval records.

Business staff must not privately agree with a seller to “swap invoices”, “supply matching invoices” or refund off the books. Where an invoice is overdue, has an error, or needs a credit note, deal with it through the original transaction and the original issuer under the law — never by sourcing a replacement invoice from a third party.

X. When the deal must stop

If any of the following appears, stop paying and taking further delivery, and escalate to the finance lead, legal or management:

  1. The seller cannot prove title, or the warehouse refuses to confirm title and unpledged status;
  2. The contract seller, payee and invoice issuer do not match, with no lawful, verifiable exception arranged;
  3. The actual goods are non-standard, secondary aluminium or something else, but invoicing as A00 ingot is requested;
  4. A request to pay a personal account, split payment, pay cash, or change the account at short notice;
  5. A request for a third party to issue the invoice, to “buy tax points”, or to supply an invoice unrelated to this deal;
  6. The invoice is credit-noted, voided or flagged abnormal, and the seller refuses to cooperate on verification and re-issue;
  7. The seller becomes uncontactable, is listed as a delinquent taxpayer, or shows a major tax violation or abnormal-operation flag;
  8. The price is markedly below the local like-for-like spot price including tax, and the seller cannot explain it by brand, region, payment terms, pledge status or upstream input — any genuine commercial reason.

A sham transaction, a third-party matching invoice, forged title, or an individual collecting a bulk-commodity payment cannot be made compliant by an internal sign-off.

XI. First-order execution checklist for A00 ingots

  1. Fix the price benchmark, region, date, average price, discount and whether tax is included;
  2. Confirm the contract seller, invoice issuer and payee all match;
  3. Complete the corporate-registry, tax, credit, operating-capacity and upstream-source checks;
  4. Contact the warehouse independently and verify brand, furnace number, bin location, weight and the goods-in note;
  5. Obtain confirmation of title, unpledged status and transfer;
  6. Count, sample and weigh on site, and retain continuous video and vehicle records;
  7. Confirm the final settlement sheet matches the contract, weight and invoice amount;
  8. Pay only to the seller's own corporate account, and only after title has transferred;
  9. Confirm the full digital special invoice has entered the buyer's tax digital account;
  10. Check the parties, product name, specification, quantity, unit price, amount, tax rate, tax and status;
  11. Confirm purpose and complete internal booking before paying the balance;
  12. File the contract, title, cargo, funds and invoice records together as one dossier per deal;
  13. Keep monitoring for credit notes, abnormal vouchers and the supplier's ongoing operating status.

The final release checklist: goods checked, title transferred, payment same-name, invoice genuine, evidence complete. If any one is missing, pause payment.

XII. One dossier per deal, and ongoing monitoring

For every deal, four electronic file groups are recommended:

File groupCore records
Admission, quotation and contractBusiness licence, general-taxpayer records, credit check, quotation, approval, contract, order and guarantee terms
Title, acceptance and transportWarehousing contract, warehouse receipt, title confirmation, transfer, quality warranty, inspection, weighing, vehicle records, photos and video
Settlement, payment and invoiceSettlement sheet, statement, approval, bank receipt, XML/PDF, verification, purpose confirmation and credit-note records
Exception handlingNotice, evidence package, tax-authority correspondence, invoice re-issue, claim and litigation files

Key suppliers should have their operating and tax status re-checked on an ongoing basis, watching the tax digital account for credit notes, abnormal vouchers and credit status. Where the price keeps drifting from the market, or the invoicing entity or the receiving account changes, re-run supplier admission. Raise the review frequency for high-risk suppliers and for any supplier whose purchase volume or invoiced amount is growing fast.

In closing: compliance is not about “having an invoice” — it is a closed transaction loop

Invoice risk in ingot purchasing does not usually appear suddenly on the day of issue. It accumulates gradually through supplier admission, title verification, payment structuring and record-keeping. As long as there is a break anywhere between the contract, the cargo, the title, the funds and the invoice, a currently-verifiable invoice cannot solve the problem on its own.

What a business genuinely needs is not a single “check it after receiving the invoice” step, but a mechanism that can pause payment, supplement evidence, escalate approval and pursue losses. A price discount is only a commercial profit worth keeping when a genuine trade, clear title, same-name payment and a valid invoice all hold true at once.

Need a compliance read on a specific ingot deal?

Crisscross Metals Trade Alliance can run a baseline risk review of a specific A00 ingot or aluminium alloy spot deal — covering the trading parties, price basis, warehouse title, acceptance records, payment milestones and invoicing arrangement. When you submit a case, please provide: the seller's company name, where the goods are located, brand and furnace/lot number, quantity, pricing basis, warehouse records, payment plan and the proposed invoicing details.

  1. Aluminium ingot, alloy and secondary feedstock
  2. Trade authenticity verification service
  3. Contact Crisscross Metals Trade Alliance
  4. Email: otto@crisscrossmetals.com
  5. Phone: +86 158 8106 2812

Primary legal and official references

  1. Value-Added Tax Law of the People's Republic of China (effective 1 January 2026)
  2. Implementing Regulations for the VAT Law of the PRC (State Council Order No. 826)
  3. Invoice Administration Measures of the PRC (State Council Order No. 764)
  4. Detailed Rules for the Invoice Administration Measures (as amended by State Taxation Administration Order No. 56)
  5. STA Announcement No. 11 of 2024, on rolling out fully digitalised electronic invoices
  6. STA Announcement No. 38 of 2019, on management of abnormal VAT deduction vouchers
  7. Tax authority public guidance on falsely issued invoices, good-faith acquisition and handling abnormal vouchers
  8. STA national VAT invoice verification platform — user guidance

Evidence note: this article draws on published tax regulations, tax-authority announcements and the control points commonly seen in A00 ingot warehouse spot purchasing. The example prices illustrate a risk ratio only and are not a live market quote or trading advice.