Agency export,Does non-refund violate national policies?

According to the latest <Export goodsAccording to the Value-added Tax and Consumption Tax Management Measures for Labor Services, agency export without tax refund is a legal operation. However, the following key points should be noted:

• Policy basis:The Ministry of Finance's revised Article 13 in 2024 clearly stipulates that foreign trade enterprises may opt for the "tax exemption without refund" method for handling export transactions.
• Scope of application:Specific business types such as processing trade with supplied materials, goods in special supervision areas, and cross-border tax-free services
• Filing requirements:The words "Tax-Free Export" must be noted in the remarks column of the customs declaration form, and the record must be completed in the electronic port system.

How to operate agency export without tax refund in compliance?

Compliant operations require establishing a complete business evidence chain. It is recommended to follow these procedures:

• The preliminary preparation phase
  • Sign a tripartite agreement (consignor, agent, foreign buyer) clarifying tax treatment methods
  • Specify VAT special invoice issuance rules in the agency agreement
• Customs declaration stage
  • The trade method declared on the customs declaration form is "general trade."
  • Supporting documents must include complete price composition explanation
• Follow-up management
  • Establish a separate tax-free export business ledger
  • Retain original contracts and payment vouchers for at least 10 years

What impact does non-refund operation have on enterprise costs?

Enterprises need to establish preciseComprehensive cost calculation models:

• Input tax transfer cost = tax-exclusive purchase price × tax refund rate difference
  • Example: The tax-inclusive purchase price is 1.13 million (13% tax rate), with a 9% tax refund rate. The transferred cost = 1 million × (13%-9%) = 40,000 yuan
• Hidden costs include:
  • Capital occupation cost (difference in tax refund recovery cycles)
  • Exchange rate fluctuation risk exposure
  • Customs valuation risk premium

Under what circumstances should non-refund be chosen?

After calculation, it is recommended to adopt the non-tax-refund scheme when the following conditions are met:

• Low-profit orders with trade profit margins below 3%
• Transit trade involving special supervision zones
• When input invoices have defects and full tax refund cannot be obtained
  • Example from a Zhejiang garment company in 2025: Due to supplier absconding, 30% of input tax could not be deducted, so the non-tax-refund scheme was chosen to reduce losses
• Export products belong to nationally restricted categories (such as rare earth deep-processed products newly added in 2025)

How to prevent legal risks in non-refund operations?

Proposal to establishFour-layer risk prevention mechanism:

• Contract risk prevention
  • Clearly specify the settlement currency and exchange rate benchmark date
• Document management standards
  • Ensure the "three documents consistency" between the customs declaration, bill of lading, and invoice.
• Tax filing system
  • Complete cross-border taxable behavior tax exemption filing in the electronic tax bureau
• Audit traceability mechanism
  • Conduct quarterly special audits for tax-exempt businesses