Value-added tax on inter-enterprise borrowing funds: first, enterprises give funds to others for use, which belongs to value-added tax loan service. According to the "Implementation Measures for the Pilot Project of Changing Business Tax to Value-added Tax", loan refers to the business activities of lending funds to others to obtain interest income. Therefore, the behavior of enterprises transferring funds to others conforms to the definition of "loan service" of value-added tax. Second, it is regarded as sales behavior that the enterprise gives the funds to others free of charge. According to Article 14 of the Pilot Implementation Measures for Changing Business Tax to Value-added Tax, the following situations are regarded as sales services, intangible assets or real estate: (1) Units or individual industrial and commercial households provide services to other units or individuals free of charge, except public welfare undertakings or the public. Therefore, the behavior of enterprises transferring funds to others for free belongs to the category of collecting value-added tax as sales and needs to pay value-added tax. The third is to regard the enterprise's transfer of funds to others for free as a sales act. Article 25 of the Regulations for the Implementation of the Enterprise Income Tax Law stipulates that: if an enterprise exchanges non-monetary assets and donates, pays debts, sponsors, raises funds, advertises, samples, employee welfare or distributes profits with goods, property and services, it shall be regarded as selling goods, transferring property or providing services, unless otherwise stipulated by the competent financial and tax authorities of the State Council. Therefore, the enterprise's transfer of funds to others for free belongs to the labor service in enterprise income tax (it should be noted that the labor service in enterprise income tax includes the service and labor service in value-added tax), which is regarded as the sales category and needs to pay enterprise income tax. Fourth, Article 3 of Caishui [20 19] No.20 stipulates that from February 20 1 9 to February 3 1 2020, the free borrowing of funds between units (including enterprise groups) in an enterprise group is exempt from VAT. Fifthly, the Provisions on the Transition Policy of Changing Business Tax to Value-added Tax 1 (9) 7 stipulates that in the unified borrowing and unified repayment business, the interest charged by the enterprise group or the core enterprises within the enterprise group and the financial companies affiliated to the group from the enterprise group or the subordinate units within the group shall be exempted from value-added tax at a rate not higher than the loan interest rate paid to financial institutions or the coupon rate level of bonds paid. Sixth, according to the first paragraph of Article 18 of People's Republic of China (PRC) State Taxation Administration of The People's Republic of China Bulletin No.2018, expenses incurred by enterprises and other domestic enterprises (including affiliated enterprises) and individuals shall be shared according to the principle of independent transaction. Enterprises use invoices and split sheets as pre-tax deduction vouchers, and other enterprises receiving taxable services use split sheets issued by enterprises as pre-tax deduction vouchers. Accordingly, if enterprise A borrows funds from the bank, the two parties jointly use the funds and share the corresponding bank interest, which does not belong to the category of the above-mentioned enterprises borrowing funds from each other as sales.