Legal basis: If the second paragraph of Article 53 of the Measures for the Implementation of the Pilot Project of Changing Business Tax to VAT falls into one of the following circumstances, a special VAT invoice may not be issued:
(1) Selling services, intangible assets or immovable property to consumers.
(2) Taxable acts exempted from the provisions of VAT. That is to say, in addition to selling services, intangible assets or real estate to consumers and taxable acts exempted from VAT, special invoices can be issued.