I.Agency export serviceWhat type of income does the fee belong to?

According to the "Implementation Regulations of the Enterprise Income Tax Law," agency export service fees fall underRevenue from modern service industriesBusiness support services in China. Specific tax treatments require attention:

• Value-added tax is levied at 6% (3% for small-scale taxpayers).
• Corporate income tax is calculated at a 25% tax rate on taxable income.
• If international transportation revenue is obtained, the value-added tax (VAT) zero-rate policy may be applied.

II.Export tax refundDo revenue shares need to be taxed?

The agreed-upon sharing of tax refunds between the agent enterprise and the entrusting party needs to be distinguished in two scenarios:

• The nature of service fee classification: Included in operating income, subject to value-added tax and corporate income tax.
• The nature of collection and payment is categorized as follows:: Complete proof of fund flow is required and shall not be treated as taxable income.
• Key Focus Areas for Tax Audits in 2025: Requirement to Provide Correspondence Between Bank Statements and Contract Terms

III. How to issue a VAT invoice for export agency business?

In accordance with the latest requirements of Announcement No. 15 [2024] from the State Taxation Administration:

• Service fee portion invoiced6% VAT special invoice
• The advanced freight and other expenses should be noted with the phrase "collection and payment on behalf."
• The amount declared on the customs declaration form must not be reflected in the invoice.
• Important Notice: The Electronic Invoice Archiving System Will Be Fully Implemented Starting from 2025

IV. What tax responsibilities does the entrusting party need to bear?

The entrusted production enterprise needs to pay special attention:

• Export goods revenue is recognized as sales income based on the FOB price.
• The tax refund received should be recorded under the "Other Income" account.
• Agency fee expenses are tax-deductible with compliant invoices.
• Transboundary PaymentsService fees must complete tax filing (as required by Announcement No. 6).

5. What are the common tax risks in export agency business?

Key areas for joint supervision by the General Administration of Customs and the State Taxation Administration in 2025:

• The cash flow does not match the invoice flow.
  • The payment account does not match the contracting party.
  • The foreign exchange settlement period exceeds 180 days without filing.
• Abnormal fluctuations in tax burden rate
  • The service fee pricing significantly deviates from industry standards.
  • The proportion of tax refund allocation exceeds the contractual agreement.
• Document management loopholes
  • The customs declaration form does not match the information on the VAT invoice.
  • Logistics documents missing or time logic error

(Note: Specific tax treatment shall be subject to the interpretation of the competent tax authority. It is recommended to conduct a tax compliance review before major transactions.)