According to Article 10 of the Notice of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC) on Printing and Distributing Business Tax Questions (Part I) (Guo Fa [1995]No. 156), "Non-financial institutions provide funds to each other and charge capital occupation fees, such as enterprises borrowing working capital and charging capital occupation fees, and the administrative organs or competent departments of enterprises will provide funds to subordinate units or enterprises and charge capital occupation fees. "Notes on Business Tax Items" stipulates that loans belong to the collection scope of "finance and insurance" tax items, and loans refer to the act of lending funds to others for use. According to this regulation, whether financial institutions or other units lend funds to others, it should be regarded as a loan, and business tax should be levied according to the tax item of "financial insurance". Any unit that only lends funds to others should be regarded as a loan, and business tax should be levied according to the tax item of "financial insurance".

Of course, according to Article 1 of the Notice of State Taxation Administration of The People's Republic of China, Ministry of Finance of People's Republic of China (PRC) on the Collection of Business Tax on Unified Lending and Repayment by Non-financial Institutions (Caishui [2000] No.7), in order to alleviate the financing difficulties of small and medium-sized enterprises, the competent departments of enterprises or core enterprises in enterprise groups (hereinafter referred to as unified borrowers) will allocate the borrowed funds to subordinate units (including independent accounting units and non-independent accounting units) after borrowing from financial institutions. And according to the loan interest rate paid to financial institutions, the interest for returning financial institutions is charged to subordinate units, and business tax is not levied. If the loan meets this condition, the interest earned will not be subject to business tax.