According to national tax2009:91According to the document, the land value-added tax liquidation of real estate projects is divided into "liquidable" and "liquidable". For the "liquidated" project, the taxpayer's land value-added tax liability of the project ends after liquidation, and there is generally no need for secondary liquidation. However, for liquidable items, there is usually a re-sale after liquidation (also known as the final sale), so there is a need for secondary liquidation.

First, the current tax policy
The current tax policy does not explicitly require the secondary liquidation, but it does not deny the secondary liquidation, which is definitely not illegal. I live in2012Around 2000, it was orally clear that a second liquidation could be carried out (later denied and terminated by the provincial bureau). Up to now, secondary liquidation is still allowed in some parts of the country. For example, Opinions of Hubei Local Taxation Bureau on Further Regulating the Collection and Administration of Land value-added Tax(Hubei tax payment [2013:44(No.) Provisions on the secondary liquidation of land value-added tax for real estate development projects: After the taxpayer meets the conditions of liquidation and carries out the liquidation of land value-added tax, the expenditure that continues to pay and obtains legal and valid vouchers can apply for secondary liquidation, provided that all costs and expenses have been fully incurred. The competent tax authorities may readjust the amount of deducted items and adjust the amount of land value-added tax payable according to the actual situation. After the secondary liquidation, the taxpayer shall not request the land value-added tax liquidation again.

There is no secondary liquidation in Jiangsu at present. For resales after liquidation, all in accordance with the state tax2006:187The document stipulates that the unit cost shall be determined and the land value-added tax payable shall be calculated on a weekly, monthly or rolling basis. Relevant policies and existing problems have been described in "one of the sensitive issues of land value-added tax", and will not be covered here.

Second, the attitude of the General Administration

The State Administration of Taxation has issued few policies related to land value-added tax, resulting in large differences in policy implementation caliber among provinces, and even in different regions within the same province there are different policy caliber. For the secondary liquidation problem, the General Administration in2014In 2005, the discussion paper was issued, and the discussion paper stipulated:

When a real estate development project meets the requirements for liquidation, the taxpayer shall conduct pre-liquidation, calculate by himself the land value-added tax amount payable for the real estate development project under the current situation, and declare and pay it in advance to the tax authorities. The declaration and advance payment shall start from the day when the land value-added tax can be liquidated90Within days. If the real estate project continues to be sold after the pre-liquidation, the pre-tax shall still be paid at the pre-tax rate previously stipulated. After all the real estate projects are completed and settled, the taxpayer shall liquidate by himself, with more refund and less compensation.

Although there were some imperfections in the provisions of the above discussion draft, it was clear that the administration supported the second liquidation at that time. Unfortunately, the above discussion draft could not be issued as a formal document.

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