Guizhou Fufa Renewable Resources Recycling and Utilization Co., Ltd. (Taxpayer Identification Number: 91522328MAD4FHC33M):

From December 15, 2025 to June 5, 2026, our bureau inspected your tax-related situation from November 9, 2023 to December 31, 2024 (address: inside the factory building of Jinbaineng Group, core section of the Industrial Park, Qifeng Subdistrict, Anlong County, Qianxinan Buyei and Miao Autonomous Prefecture, Guizhou Province). The illegal facts and penalty decision concerning you are as follows:

I. Illegal facts and evidence

(I) Falsely issuing value-added tax invoices

During the period from December 2023 to May 2024, your company issued 4 electronic special value-added tax invoices to Guizhou Haolin Holdings (Group) Co., Ltd. (hereinafter referred to as “Haolin Holdings”), with invoice numbers 23522000000002178453, 24522000000001325690, 24522000000013438808, and 24522000000019014234. The goods name was steel plate, the quantity was 149.16 tons, the amount was 528,198.02 yuan, the tax amount was 5,281.98 yuan, and the total price including tax was 533,480.00 yuan.

Upon investigation, your company, without any genuine purchase or sale of goods with Haolin Holdings, issued the above invoices through fund backflow. This conduct constitutes issuing special value-added tax invoices for others that do not correspond to the actual business operations, and has constituted false invoicing.

Legal basis: Article 21 of the Measures of the People’s Republic of China for the Administration of Invoices (third amended in accordance with the Decision of the State Council on Amending and Repealing Certain Administrative Regulations dated July 20, 2023) provides: “Invoices shall be issued truthfully in a single instance for all copies in accordance with the prescribed time limits, sequence, and columns, and paper invoices shall be affixed with the special invoice seal. No entity or individual may engage in the following acts of falsely issuing invoices: (1) issuing invoices for others or for oneself that do not correspond to the actual business operations; (2) having others issue invoices for oneself that do not correspond to the actual business operations; (3) introducing others to issue invoices that do not correspond to the actual business operations.”

The above illegal facts are proven by the following evidence:

1. Your company’s invoice register; 2. Your company’s accounting vouchers and attachments, and copies of invoices; 3. Accounting and accounting-related materials for the relevant business between your company and Haolin Holdings; 4. Relevant bank transaction records and fund flow diagrams; 5. Inquiry records of relevant personnel.

II. Penalty decision

In accordance with the provisions of Paragraph 1 of Article 35 of the Measures of the People’s Republic of China for the Administration of Invoices (Guo Han [1993] No. 174) (third amended in accordance with the Decision of the State Council on Amending and Repealing Certain Administrative Regulations dated July 20, 2023 (Order No. 764 of the State Council of the People’s Republic of China)), which states: “Where invoices are falsely issued in violation of the provisions of these Measures, the tax authorities shall confiscate the illegal gains; where the falsely issued amount is not more than 10,000 yuan, a fine of not more than 50,000 yuan may also be imposed; where the falsely issued amount exceeds 10,000 yuan, a fine of not less than 50,000 yuan but not more than 500,000 yuan shall also be imposed; where a crime is constituted, criminal liability shall be pursued in accordance with the law.” Your company, under circumstances where there was

no actual transaction, issued 4 special value-added tax invoices to Haolin Holdings, with a total amount of 528,198.02 yuan. The above conduct constitutes false invoicing. A fine of 100,000.00 yuan is imposed on your company for the act of falsely issuing invoices.

The total amount payable above is 100,000.00 yuan. Your company is required to make payment to the Anlong County Tax Service, State Taxation Administration, within fifteen days from the date of service of this decision. If the fine is not paid when due, our bureau may, in accordance with Item (1), Paragraph 1 of Article 72 of the Administrative Penalty Law of the People’s Republic of China, impose an additional fine of 3% of the fine amount per day.

If you disagree with this decision, you may apply for administrative reconsideration to the Qianxinan Buyei and Miao Autonomous Prefecture Tax Service, State Taxation Administration, in accordance with the law within sixty days from the date of receipt of this decision, or bring a lawsuit before a people’s court in accordance with the law within six months from the date of receipt of this decision. If, upon expiration of the time limit, you neither apply for reconsideration nor bring a lawsuit before a people’s court, and fail to perform the penalty decision, our bureau has the right to take compulsory enforcement measures prescribed in Article 40 of the Law of the People’s Republic of China on the Administration of Tax Collection, or apply to a people’s court for compulsory enforcement.

June 5, 2026