Agency export,Who is responsible for issuing the special invoice?

According to the latest 2025 "Provisional Regulations on Value-Added Tax," the special VAT invoices for export agency services must be issued byActual supplierIssue. The agency company, as the service provider, only providescustoms clearanceLogistics and other services shall not replace production enterprises in issuing invoices. Special attention should be paid to the following in specific operations:

• The invoice title should be the overseas purchaser.
• The product name must exactly match the customs declaration form.
• The phrase "acting as export agent" and the agency agreement number must be noted.

What are the essential materials required for an agency export special invoice?

Announcement No. 38 of the General Administration of Customs in 2025 clearly requires that the following documents must be prepared for issuing special VAT invoices for export agency services:

• Basic files
  • Original Tripartite Agency Agreement
  • Proforma Invoice
  • Packing List and Quality Inspection Report
• Trade documents
  • Foreign exchange receipt certificate
  • Electronic Port Customs Declaration Receipt
  • Copy of transport document

What are the mandatory regulations regarding the issuance time of special invoices?

According to the latest interpretation by the State Taxation Administration in 2025:

• After the goods depart from the port.Within 15 working daysMust be issued
• After the foreign exchange is credited30 daysComplete the internal bill filing.
• The deadline for tax refund declaration is the following year after the export.April 30 of the following year

How is the amount of the special invoice for export agency determined?

Strict adherence is required.The "subject-verb agreement" rule:

• Invoice amount = Customs declaration amount = Foreign exchange receipt amount
• The exchange rate conversion adoptsThe Bank of China's spot exchange buying rate on the day of customs declaration.
• Commissions involved shall be listed separately and supported by payment vouchers.

How to prevent common risks?

Based on the 200+ cases we have handled, special attention should be paid to:

• Beware of the "Fictitious Export" Trap
  • Verify the import and export rights qualification of the agency company.
  • Verify the information on the Customs Electronic Port IC Card.
• Preventing Defects in Bills
  • Ensure the HS code matches the customs declaration form.
  • Verify the unit of measurement against the customs declaration data.

What are the new changes in the 2025 tax rebate policy?

The adjustment plan released by the Ministry of Finance in March 2025 shows:

• The tax rebate rate for mechanical and electrical products has been raised to 13%.
• Added newCross-border e-commerceB2BExport tax refundFast track
• Abolish the paper verification form and fully implement electronic tax refunds.

What is the difference between invoicing for export through an agent and self-operated export?

From a practical operational perspective, the comparison is as follows:

• Differences in invoicing entities
  • Self-operated export: Production enterprises directly issue invoices.
  • Agency export: The production enterprise is still required to issue invoices.
• Division of responsibilities
  • In agency mode, the customs declaration errors shall be borne by the agent.
  • Self-operated exports require bearing all risks independently.

What should cross-border e-commerce operators pay special attention to?

New requirements for B2C export business:

• Applications can be submitted for single tickets with an amount below 5,000 yuan.Simple Invoice
• Please provide a screenshot of the platform transaction data.
• Please note the label "Cross-border E-commerce Retail Export."

How to choose a compliant agency company?

It is recommended to evaluate from the following dimensions:

• Verify the AEO certification level (preferably select enterprises with advanced certification).
• Verify the completeness of foreign exchange income and expenditure declaration records
• Please provide successful tax refund cases from the last 3 months.
• Verify the validity of electronic port operation permissions.