Agency export,Where exactly does the price difference come from?

According to the latest international trade practices in 2025, the agency export price difference mainly occurs in the following scenarios:

• Exchange rate fluctuation arbitrage: The agent locks the exchange rate through forward foreign exchange settlement, forming a price difference with spot foreign exchange settlement
• Tax rebate time difference:Export tax refund: The adjustment cycle of the rate does not match the execution cycle of the agency contract
• Service fee splitting: The agency service fee is converted into a unit price difference of goods for settlement
• Market protection mechanism: Adjust the declared price and the actual transaction price at the request of the brand owner

How should the agency price difference be calculated legally in 2025?

According to Announcement No. 20251 of the General Administration of Customs, the calculation of compliant price differences needs to meet the following conditions:

• The price difference range does not exceed 10% of the declared amount (except for bulk commodities)
• A complete chain of payment vouchers must be retained
  • Payment receipt of the overseas buyer
  • Transfer record of the domestic agent
  • Bank foreign exchange settlement voucher
• The nature of the price difference part needs to be clearly stated in the agency agreement
  • The tax rate of the service fee price difference must be listed separately
  • The exchange rate difference needs to be attached with a bank quotation certificate

What tax risks will the agency price difference bring about?

The real cases we handled in 2024 show that the main risks are concentrated in:

• The value added tax chain is broken: A certain enterprise was required to pay back taxes + late fees of 420,000 yuan due to the unissued invoices for the price difference part
• Transfer pricing investigation: A multinational group paid an additional 1.8 million US dollars in income tax due to the excessive price difference in related party transactions
• Abnormal foreign exchange verification: When the difference between the foreign exchange receipt amount and the declared amount exceeds 5%, it will trigger a verification by the foreign exchange administration

What are the new regulations for handling price differences in 2025?

The latest policies of the State Administration of Foreign Exchange require:

• Establish a price difference early - warning mechanism (automatically file for single - transaction amounts exceeding $50,000)
• Launch an electronic price difference filing system (to be launched on June, 2025)
• Expand the tolerance for currency settlement price differences (the RMB settlement is relaxed to 15%)

How to design a compliant price difference handling plan?

It is recommended to adopt a "three-stage" processing framework:

• Contract structure
  • Main contract: Sign according to the declared customs value
  • Supplementary agreement: Clarify the nature of the price difference and the handling method
• Capital path
  • Directly remit to the overseas manufacturers account
  • Pay the price difference part under the service trade item
• Certificate management
  • Keep complete email communication records
  • Prepare a separate price difference settlement statement

What should be done in case of sudden price difference disputes?

Based on our experience in handling cross - border trade disputes, the following steps are recommended:

• Immediately freeze the disputed funds (through a bank payment stop order)
• Apply for a commercial certificate from the China Council for the Promotion of International Trade
• Initiate the customs price pre - ruling procedure
• Consider insuring the price difference clause of export credit insurance