Taxation on Container-Covered Mobile Houses

The taxation issues concerning container-covered mobile houses require a comprehensive analysis based on the type of enterprise, the nature of its business, and tax policies. The key points are as follows:

I. VAT Payment Rules

1. VAT Rate for General Taxpayers
   If an enterprise is a general VAT taxpayer (such as Tianjin Xinfangyuan, Yichang Heyiyuan, Hangzhou Xiangtai, etc.), the sale or lease of container mobile houses generally applies a 13% VAT rate. For example, Tianjin Xinfangyuan, as a general VAT taxpayer, calculates taxes on its container leasing services at this rate.

2. Preferential Rates for Small-Scale Taxpayers
   If an enterprise is a small-scale taxpayer (such as Xuchang Fangxin, which is not explicitly labeled as a taxpayer but is relatively small in scale), it may apply a 3% or 1% collection rate (preferential rates during the pandemic period), subject to verification by the local tax authority.

3. Export Tax Rebate Policy
   If mobile houses are used for export (such as mobile homestay pods), they are classified as 'other movable houses' (tax number 9406900090) according to the 2026 customs HS code rules and are eligible for a 13% export tax rebate rate. Enterprises need to file for registration through the electronic tax bureau or the international trade 'single window' and ensure 'four-flow consistency' (contract, goods, funds, and invoice flows) to comply with regulations.

II. Corporate Income Tax Treatment

1. Income Recognition Timing
   Corporate income tax is settled and paid annually, with income recognition following the accrual basis. For example, sales revenue from container mobile houses is recognized upon delivery, while leasing income is recognized based on the payment cycle stipulated in the contract.

2. Deductible Cost Items
   Deductible costs include raw material procurement (such as steel and glass), production and processing expenses, transportation and installation costs, and equipment depreciation. For example, Guangdong Zhonghui Lvjian can legally deduct raw material costs and R&D expenses when producing quick-assembly containers and pods.

III. Tax Treatment for Special Business Scenarios

1. Mixed Sales and Concurrent Business Operations
   If an enterprise provides both container sales, leasing, and installation services (such as Tianjin Xinfangyuan), it needs to distinguish the nature of its business:

   • Sales + Installation: If the installation service is not separately priced, VAT is paid on the sale of goods; if separately priced, the installation service is taxed at a 9% rate (classified as construction services).
   • Leasing + Maintenance: The leasing service is taxed at 13%, while the maintenance service is taxed at a 6% rate (if classified as modern services).

2. Cross-Regional Business Taxation
   If an enterprise undertakes projects in other regions (such as the installation of cultural tourism homestay container houses in Hubei), it needs to prepay VAT and corporate income tax at the project site and settle accounts at its institutional headquarters.

IV. Compliance Recommendations

1. Accurate Classification of Commodity Codes
   Avoid misclassifying container mobile houses as 'steel structural components' (with a 9% rebate rate) or 'containers' (with a 10% rebate rate), as this may result in tax supplements and late fees.

2. Retention of Supporting Documents
   Export enterprises need to retain contracts, packing lists, bills of lading, and other documents for verification by the tax authority regarding the authenticity of tax rebates.

3. Monitoring Policy Updates
   For example, in September 2025, the Ministry of Commerce increased the tax rebate rate for 'prefabricated travel pods' from 9% to 13%. Enterprises need to adjust their declaration strategies promptly.