According to Article 1 of the Notice of the Ministry of Finance and State Taxation Administration of The People's Republic of China on Stamp Duty Policy on Financial Leasing Contracts (Caishui [215] No.144), financial leasing contracts (including financing sale and leaseback) signed to carry out financial leasing business shall be uniformly taxed and stamped according to the total rent stated in them and the tax item of "loan contract". It is clear here that the financial lease contract is subject to stamp duty according to the tax item of "loan contract". ?

at the same time, article 2 of the notice stipulates that in the financing sale and leaseback business, stamp duty is not levied on the contracts signed by the lessee and lessor for the sale and repurchase of leased assets. It should be emphasized that this clause is only applicable to the purchase behavior in the financing sale and leaseback business, that is, when the lessee and the seller are the same subject. However, when the seller is an independent third party, the purchase contract signed by the lessor and it also needs to be subject to stamp duty according to the tax item of "purchase and sale contract". Finally, taxpayers need to be reminded that Article 3 of the notice stipulates that this notice shall be implemented as of the date of issuance. Matters not handled before shall be implemented in accordance with the provisions of this notice. Therefore, this notice has retrospective effect.