I.Agency export,Who on earth should declare for tax refund?

According to the current [2025]Export goodsMeasures for the Administration of Value - Added Tax and Consumption Tax on Labor Services. The agency export business must comply with these measures."Who operates, who declares"Principle:

• Entrusting PartyWhen holding the ownership of the goods:
  • It needs to be handled by yourself.Export tax refundrecorded
  • Submit to the tax authoritiescustoms clearanceFull set of documents such as single - agent agreements, etc.
• AgentWhen only providing customs declaration services:
  • The words "Agent" must be indicated in the "Declaring Entity" column of the export customs declaration form.
  • Submit the original Power of Attorney for Customs Declaration to the customs

Special Note: According to Announcement No. 79 of 2024 by the General Administration of Customs, starting from January 2025, all agency customs declarations must upload electronic power of attorney through the International Trade "Single Window," and paper documents will no longer be accepted separately.

II. When should the tax liability for income from agency export be recognized?

There are differences in the recognition time points of value - added tax and enterprise income tax:

• Value-added tax liability for payment
  • It shall be subject to the actual date of goods leaving the country (the customs declaration form for export goods issued by the customs is required)
  • The foreign exchange should be collected at the latest before the VAT tax return period in April of the following year after export.
• Enterprise Income Tax Revenue
  • Recognize revenue on an accrual basis
  • It is recommended to recognize revenue when obtaining a copy of the bill of lading (B/L).

Case Warning: In 2024, a foreign - trade company failed to collect foreign exchange within the specified time limit, resulting in the recovery of the already - refunded tax and an additional late - fee of 380,000 yuan.

III. How to issue invoices for agency service fees in compliance?

The service fees collected by the agent need to be handled in two different situations:

• Pure agency service
  • Issue a 6% VAT special invoice under "Business Support Services - Brokerage and Agency Services".
  • Please indicate "Agency Export Service" in the remarks column.
• Situations of assuming the purchase and sales risks
  • It should be treated as self - operated export.
  • Goods sales invoices need to be issued at a tax rate of 13%.

Risk Warning: The focus of tax audits in 2025 will include illegal invoicing practices such as "disguised sales under the guise of agency." Violators may face fines of up to three times the amount involved.

IV. Which missing documents will lead to the inability to claim tax rebates?

According to 2025Export tax refundThe latest requirement is that the following documents must be prepared:

• The electronic version of the export goods declaration form verified by the customs
• Complete foreign exchange receipt voucher
  • Bank settlement slip must include SWIFT CODE
  • For cross - border RMB settlement, messages of the RCPMIS system need to be provided.
• Notarized agency agreement (Chinese and English versions)
• Value - added Tax Special Invoice issued by the principal (in the case of self - operated export)

Special Reminder: Starting from 2025, the tax authorities will automatically compare the data of the customs, the State Administration of Foreign Exchange, and the tax bureau through the Golden Tax Phase IV system.

V. How to prevent tax risks in agency export?

It is recommended that enterprises establish a triple - risk prevention and control mechanism:

• Agreement Signing Stage
  • Clearly stipulate the filling specifications of the customs declaration form
  • Agree on the time limit for document transmission (it is recommended not to exceed 15 working days)
• Business Execution Phase
  • Check the customs export date and foreign exchange receipt date every month.
  • Establish an inspection checklist for the completeness of tax refund materials
• Post - Declaration Management
  • Preserve the complete set of materials for at least 10 years
  • Regularly conduct compliance audits of export tax rebates

Special Notice: According to the new regulations from the Ministry of Finance in 2025, export agency businesses must complete "Special Case Filing" on the electronic tax platform. Enterprises that fail to file will experience delays in tax refund processing.