国家税务总局发布并已在实践中实施的《增值税专用发票使用规定》中有关专用发票开具时限明确规定:“采用赊销、分期付款结算方式的,为合同约定的收款日期的当天”。可见,在分期付款结算方式下,销货方不应在交付商品的当时即向购货方填开专用发票,而应在合同约定的收款日期的当天向购货方填开专用发票。值得注意的是,在这种结算方式下,若销货方在交付商品时即向购货方填开专用发票,则此时即产生了纳税义务,而此时尚未到约定的收款日期,意味着销贷方主动将纳税义务提前了,显然于己不利。同时,也意味着购货方在约定的付款日期之前,先行获得了税款抵扣的合法凭证,从而在付款之前可以提前抵扣税款,这显然是不公平的。因此,笔者以为,在分期付款结算方式下,销货方应严格遵照《增值税专用发票使用规定》,在“合同约定的收款日期的当天”才应向购货方填开专用发票。此处还需注意的是,若合同约定分多期收款,则不 The time limit for issuing special invoices issued by the State Administration of Taxation and implemented in practice stipulates clearly: “The day of the collection date agreed in the contract by means of credit and installment settlement” . Therefore, under the installment settlement method, the seller should not fill out the special invoice to the buyer at the time of delivery of the goods, but should fill in the special invoice to the buyer on the day when the contract was agreed. It is noteworthy that, in this settlement method, if the seller in the delivery of goods to the buyer to fill a special invoice, then the tax liability arising at this time, but at this time has not yet reached the agreed collection date, It means that the seller and lender take the initiative to pay tax obligations ahead of schedule, apparently at a disadvantage. At the same time, it also means that the buyer has obtained the legitimate certificate of tax deduction before the agreed payment date, so that it is obviously unfair to debit the tax before the payment is made. Therefore, I believe that under the installment settlement method, the seller should strictly follow the “VAT invoices for use” in the “contract date of the collection date ” should only fill out the invoice to the buyer . It should also be noted here that, if the contract agreed to pay in multiple installments, no