24 August, 2004, article of Mr. Lu Guoyang, Reciprocal Issuing VAT Invoices Shall Beware of Criminal Consequences, was published on tax planning column of China Taxation News. In his work Lu pointed out that, reciprocal issuing VAT invoices without virtual goods trade, with the aim to ‘increase?sales turnover to be recognized as Normal Taxpayer for another fiscal year, is illegal according to Chinese Criminal Law and will lead to severe consequences. Some people may think since it doesn’t hurt the national revenue, it won't produce serious results. However, it was actually proved very risky.