Agency export serviceIs VAT required to be paid on the fee?

According to the "Notice of the Ministry of Finance and the State Tax Administration on Comprehensively Promoting the Pilot Program of Replacing Business Tax with Value-Added Tax" (Cai Shui〔2016〕No.36), agency export services belong to brokerage and agency services in modern service industries and are subject to value-added tax at a rate of 6%. Special attention should be paid to the following two declaration points:

• Service Fee Income Declaration: The collected agency service fees shall be fully included in the taxable sales amount.
• Processing of Collected Payments: The payments collected on behalf of customers, such as payment for goods and freight, should not be included in revenue.

How do foreign trade comprehensive service enterprises handle it?Export tax refund?

According to the newly revised "Announcement on Issues Concerning Tax Refunds (Exemptions) for Export Goods by Foreign Trade Comprehensive Service Enterprises" in 2025, the "dual抬頭" (dual抬頭 is a professional term, which can be translated as "dual-title" or retained as "dual抬頭" depending on specific context; here it is kept as in the original text as per requirements) is adopted.customs clearanceIn mode:

• As the actual seller, the manufacturing enterprise shall make the declaration by itself.Export tax refund
  • A special VAT invoice and a customs declaration form for export goods are required.
  • The tax refund entity and the foreign exchange collection entity must be consistent.
• Agency service enterprises shall recognize revenue only on service fees.
  • Costs and expenses related to agency services need to be accounted for separately.
  • Keep complete vouchers of the foreign trade service process for future reference

How to avoid tax risks in cross-border payments and receipts?

Enterprises conducting business through the proxy export model should pay special attention to the following fund management regulations:

• The Principle of Foreign Exchange Revenue and Expenditure Matching: The foreign exchange collection account must be consistent with the operating entity indicated on the customs declaration form.
• Three types of account differentiation management:
  • Special Account for Payment for Goods (Direct Payment by Overseas Customers)
  • Service Fee Settlement Account (Payment by Domestic Enterprises)
  • Special Account for Advanced Expenses (Payment Voucher Required)

What documents must be kept for agency export business?

To respond to tax authority inspections, it is recommended that enterprises completely retain the following documents for at least 5 years:

• Original Agency Service Agreement (with clear stipulation of rights and obligations of all parties)
• Bank Receipt and Payment Advice and Foreign-related Income Declaration Form
• Copies of Export Declaration and Packing List
• Basis for Service Fee Calculation and Payment Voucher

What are the new changes in agency export in 2025?

According to the revised version of the "Measures for the Administration of Tax Exemption on Cross-border Taxable Behaviors" issued by the State Taxation Administration in January 2025:

• Electronic Filing Requirements: All agency export contracts must be filed in the Electronic Port.
• Data Matching Mechanism: Customs declaration data, foreign exchange collection data, and invoicing data need to realize automatic comparison.
• Credit Management System: Enterprises with no violations for three consecutive years may apply for a simplified declaration process

Special reminder: Since the implementation of the export tax rebate policy for foreign trade comprehensive service enterprises in 2014, more than 200 enterprises have been subject to administrative penalties for irregular declarations. It is recommended that enterprises must conduct program demonstration with professional tax institutions before carrying out agency export business to avoid economic losses caused by misunderstanding.