article 2 of the provisional regulations on land value-added tax stipulates: "units and individuals who transfer the right to use state-owned land, buildings and their attachments on the ground (hereinafter referred to as the transfer of real estate) and obtain income are taxpayers of land value-added tax (hereinafter referred to as taxpayers), and shall pay land value-added tax in accordance with these regulations". It can be seen that the land value-added tax is a kind of property tax levied on the transfer of real estate, and accordingly, the equity transfer does not involve land value-added tax. However, with the publication of the document "Reply of State Taxation Administration of The People's Republic of China on the Collection of Land Value-added Tax for the Transfer of Real Estate in the Name of Equity Transfer" (Guo Shui Han [2] No.687), the original simple and clear policy has become complicated. Document No.687 of Tencent Zhongchuang Space Tax Letter [2] stipulates that your request for instructions on the collection of land value-added tax for the transfer of real estate in the name of equity transfer (No.32 [2] of Guangxi Local Taxation News) has been received. In view of the fact that Shenzhen Energy Group Co., Ltd. and Shenzhen Energy Investment Co., Ltd. transfer 1% equity of Shenzhen Energy (Qinzhou) Industrial Co., Ltd. at one time, and these assets in the form of equity are mainly land use rights, above-ground buildings and attachments, it should be taxed according to the provisions of land value-added tax after research.