Editor’s Note: In December 2025, among the three tax-related illegal cases of platform enterprises publicly exposed in a concentrated manner by the State Taxation Administration, the case of fraudulent issuance of special value-added tax (VAT) invoices by Shaanxi YunMendi Company attracted widespread attention. The limited information disclosed by the authorities outlines the characteristics of false invoicing by shell companies. However, for a platform enterprise that had legally obtained the online freight qualification, whether its operation was completely divorced from real business remains to be carefully examined.At a time when the judicial interpretations of the Supreme People’s Court and the Supreme People’s Procuratorate (the “Two Supreme Courts”) have narrowed the scope of the crime of false invoicing and emphasized the principle of the unity of subjectivity and objectivity, the judicial characterization of the YunMendi case will not only determine the fate of the involved enterprise and hundreds of downstream invoice-receiving enterprises, but also exert a profound impact on the development of the online freight industry. This article calls for a rational view of the “invoice economy”, advocates prudent distinction between real business and illegal operations, and leaves sufficient room for the standardized development of emerging business formats.

01 Basic Facts of the YunMendi Case

In December 2025, the Shaanxi Provincial Taxation Bureau exposed the case of YunMendi Company suspected of fraudulently issuing special VAT invoices. According to information released by tax authorities, between 2020 and 2022, the company accepted 2,028 fraudulently issued special VAT invoices with a total price and tax amount of 1.304 billion yuan; it externally issued 4,411 fraudulently issued special VAT invoices with a total price and tax amount of 1.855 billion yuan.

In March 2024, the Inspection Bureau of Xi’an Municipal Taxation Bureau characterized the invoices issued by the company as fraudulently issued, and transferred clues of 379 downstream invoice-receiving enterprises to relevant tax authorities for investigation and punishment. Public security organs have arrested 6 major criminal suspects, and the case has now entered the judicial trial stage. It should be noted that the information officially disclosed is only part of the clues from the tax inspection and investigation stage, not the facts finally determined by the court, and inevitably has information limitations.

Tax authorities pointed out that the input invoice structure of YunMendi Company was seriously abnormal. Taking 2021 as an example, the 1,665 special VAT invoices obtained from 8 upstream enterprises, with a total price and tax amount of 1.088 billion yuan, were all “fuel invoices”, accounting for nearly 100% of the total input VAT amount for that year. This phenomenon is indeed different from the cost structure of conventional online freight platforms, but it does not necessarily constitute a fundamental denial of the authenticity of the business.

The abnormally high proportion of fuel invoices in YunMendi may have reasonable causes: the logistics industry has an affiliated operation model for individual drivers, a large number of individual drivers connect with the platform uniformly through fleets, and refined oil is uniformly purchased and invoiced by the platform or fleets, resulting in input invoices being concentrated as fuel invoices. Other input items such as road and bridge tolls and vehicle maintenance fees may not be fully reflected in the books due to reasons such as individual drivers failing to provide invoices in a timely manner or non-standard financial collection by the platform, rather than such costs not occurring at all in the business.

In terms of the determination of business authenticity, clues disclosed by tax authorities—such as contracts without amounts, mismatched information, and drivers being unaware of the platform—are also insufficient to completely deny YunMendi’s real business operations.

First, standard framework contracts are common in the online freight industry. Many platforms, to improve operational efficiency, first sign framework agreements with carriers and then supplement details such as specific amounts, routes and goods according to actual transportation businesses. It is biased to determine that the business is false solely because the contract does not specify the specific amount.

Second, some drivers stated that they had never heard of the platform, a phenomenon that is not uncommon in affiliated industry operations. Individual drivers are usually affiliated with fleets, which uniformly connect with the platform and settle fees; drivers only need to know the person who assigns tasks and pays salaries, and are unaware of the name of the upstream platform, which cannot be directly equated to false platform business.

02 Model Differences Between the YunMendi Case and the Shenshi Shengxin Case

The exposure of the YunMendi case inevitably reminds people of the previously high-profile Zhejiang Shenshi Shengxin case. As an online freight platform, Shenshi Shengxin Company mainly matched shippers and vehicle owners through intermediation and enjoyed local fiscal rebate policies. During the involved period, it issued a total of 18,323 special VAT invoices with a tax amount of over 827 million yuan, some of which were “supplementary invoices” for real transportation businesses.

In the first instance, the principal offender was sentenced to 15 years in prison for the crime of fraudulently issuing special VAT invoices. In the second instance, after the issuance of the tax-related judicial interpretations by the Two Supreme Courts, the conviction was changed to the crime of illegally selling special VAT invoices, and the principal offender was sentenced to 10 years in prison. The main reason for the conviction change was that there was no evidence proving that the platform knew that the invoice-receiving enterprises defrauded taxes, nor was there evidence of a conspiracy to defraud taxes, so it did not meet the subjective elements of the crime of fraudulently issuing special VAT invoices and should be characterized as the crime of illegally selling special VAT invoices.

However, although the second-instance conviction change in the Shenshi Shengxin case reflected the narrowing of the crime of fraudulent invoicing of special VAT invoices, its one-size-fits-all characterization of all invoicing acts as the crime of illegally selling special VAT invoices is still debatable.

One of the core functions of online freight platforms is to issue invoices on behalf of subjects such as individual drivers who cannot issue special VAT invoices by themselves. It was clearly confirmed in the Shenshi Shengxin case that some invoicing acts corresponded to real transportation businesses. Even if there were some illegal supplementary invoicing or non-standard management, the real business part and the non-real business part should be evaluated separately. Lumping all invoicing acts into the crime of illegal sale not only denies the normal business functions of the platform, but also deprives downstream enterprises that should legally deduct input taxes of their deduction rights because the invoicing party was convicted, violating the principle of tax neutrality.

Compared with the Shenshi Shengxin case, the YunMendi case has a more prominent abnormal input invoice structure and indeed faces more severe criminal risks. However, this does not mean that the qualitative logic of the Shenshi Shengxin case can be directly applied to simply classify the YunMendi case as violent false invoicing by a shell company for severe punishment.

The YunMendi case also requires prudent distinction between real business and illegal operations. If YunMendi Company can prove that some of the invoices it issued externally correspond to real transportation businesses, this part of the business should not be evaluated as false invoicing or illegal sale. Regarding the abnormal fuel invoice input, it can be argued that it is an act of increasing input tax within the scope of taxable obligations to underpay its own taxes, which is more appropriately characterized as the crime of tax evasion in accordance with the judicial interpretations of the Two Supreme Courts and the adjudication rules of relevant typical cases.

03 Rational View of the “Invoice Economy” and Sufficient Space for Emerging Business Formats

After the exposure of the YunMendi case, the underlying invoice economy has once again become a hot topic. The National Tax Work Conference held on January 28, 2026 clearly proposed to thoroughly rectify tax-related problems of illegal investment promotion and the “invoice economy”. However, this does not mean that the invoice economy itself is an illegal chaos, let alone demonize it.

Invoicing is a normal certificate in market economic activities and the basis for enterprises to pay taxes in compliance and deduct taxes. Excessive denial of invoicing acts is not conducive to the healthy development of emerging business formats such as online freight.

It is necessary to clearly distinguish between illegal invoice economy and normal invoicing acts. What is severely rectified is the illegal invoice economy in which some local governments, to complete economic indicators, attract shell enterprises with no physical presence, no personnel and no real business to settle through excessive fiscal rebates and rewards, creating false prosperity through fraudulent invoicing. This model will indeed cause fiscal idling, tax loss and damage to fair market competition, and must be rectified.

However, the act of online freight platforms issuing invoices based on real businesses and issuing invoices on behalf of individual drivers is an inevitable demand for industry development and an important part of tax collection and administration, which should not be included in the scope of rectification. Nor should the normal invoicing demand of the entire industry be denied due to the illegal acts of some enterprises.

As an emerging business format, online freight is inevitably faced with problems such as non-standard financial operations and difficulties in input invoice collection during its development. As important participants in the transportation industry, most individual drivers cannot issue special VAT invoices by themselves. The invoice-issuing function of online freight platforms not only solves the invoicing problem for individual drivers, but also protects the legal deduction rights of downstream enterprises, which is of great significance to promoting the large-scale and standardized development of the logistics industry.

If the “invoice economy” is fully demonized, leading platforms to dare not issue invoices normally and enterprises to dare not deduct taxes in compliance, it may instead force some businesses to go underground, aggravate the chaos of false invoicing, and be detrimental to the healthy development of the industry.

04 Enterprise Risk Tips and Response Suggestions

From the current progress of the YunMendi case, the principal offenders involved face a sentencing expectation of more than ten years in prison. The case is still under court trial and no effective judgment has been made, which provides valuable space for enterprises to seek a turnaround and conduct legal defense.

Based on the above analysis, the key to the YunMendi case lies in whether the characterization of “shell company” can be negated, whether the existence of real business can be proved, and thus strive for a lighter conviction or even acquittal. Meanwhile, the 379 downstream invoice-receiving enterprises transferred for investigation and punishment can also protect their rights and interests through legal channels.

For YunMendi Company and involved personnel:

It is recommended to comprehensively sort out evidence of real business. The enterprise should systematically organize shipper entrustment contracts, actual carrier information, real waybill records during the involved period, including Beidou navigation tracks, cargo handover vouchers, freight payment vouchers, etc., to prove that it did provide transportation business matching services and was not an idling platform essentially engaged in invoicing. Even if some businesses have problems such as non-standard materials and mismatched information, it can be argued that they are industry operation practices or financial collection errors, rather than deliberate fabrication of business. If there is indeed an act of reducing its own tax burden through fuel invoice deduction, it can be argued that the subjective purpose is to underpay its own taxes, and the act of falsely offsetting input tax within the scope of taxable obligations is more in line with the characteristics of the crime of tax evasion.

For downstream invoice-receiving enterprises:

It is recommended to immediately conduct a comprehensive self-inspection. Sort out transaction contracts, logistics documents, capital flows, invoice information, etc. with YunMendi Company, focusing on proving that there are real business transactions with YunMendi, and that they are unaware of YunMendi’s illegal acts and have no subjective intent.

If the conditions stipulated in the Notice of the State Taxation Administration on Issues Concerning the Handling of Special VAT Invoices Fraudulently Obtained by Taxpayers in Good Faith (Guo Shui Fa [2000] No. 187) are met, it can be claimed that the invoices were obtained in good faith, no administrative penalty shall be imposed, and only taxes shall be made up. If notified by tax authorities for assisted investigation, the enterprise shall truthfully explain the situation, actively provide proof materials of real business, take the initiative to make up taxes and late fees, and strive for mitigated or reduced punishment from tax authorities.

For enterprises with large involved amounts and potential criminal risks, professional tax lawyers should be entrusted in a timely manner to intervene, evaluate legal risks, communicate defense opinions with tax and judicial authorities, and file administrative reconsideration or litigation if necessary. In addition, when cooperating with online freight platforms in the future, the enterprise shall verify the platform qualification, review its business compliance, ensure real business, clear capital flow and matching invoices with business, and completely keep evidence materials such as contracts, waybills, tracks and payment vouchers.