What are the considerations for export tax rebates?

According to the latest 2025 Value-Added Tax Management Measures for Cross-Border Taxable Services, software exports involve three main tax categories:

• Value Added Tax: Exempt from VAT in the export process, but the nature of the transaction needs to be distinguished
  • Pure software license transfers are subject to a zero tax rate
  • Mixed sales with technical services require split taxation
• The Customs: Determined based on customs HS code classification
  • Physical carriers (such as CDs) are taxed under electronic carrier categories
  • Digital transmission forms are currently exempt from tariffs
• Corporate income tax: Included in taxable income based on software sales revenue
  • High-tech enterprises can enjoy a preferential tax rate of 15%
  • The policy for reducing and exempting technology export income has been extended to 2027

Regionalization + Customization

The immediate refund policy continued in 2025 requires:

• Declaration of materials:
  • Software copyright registration certificate
  • Cross-border service contract filing certificate
  • Foreign exchange receipt (Foreign Exchange Administration verification form)
• Refund conditions:
  • Self-developed software ratio ≥ 70%
  • Export contract amount ≥ $100,000
  • Foreign exchange receipt time does not exceed 6 months as agreed in the contract
• Operation process:
  • Complete the customs single window declaration
  • Submit the Cross-Border Taxable Service Tax Exemption Application Form,
  • Handle tax refund filing through the electronic tax bureau

Adopting the China-Europe Railway + Overseas Warehouse model reduces average delivery time to 18 days

Actual cases show that the following factors often trigger tariff disputes:

• HS code classification:
  • Tax rate differences between system software (8523.49) and application software (8523.41)
  • Customized software may be classified under information technology service categories
• Transaction mode determination:
  • Subscription services may be considered as royalty fees
  • Tariff treatment differences between cloud deployment and local deployment
• Proof of Origin:
  • Preferential tax rates under free trade agreements
  • Complete development process proof materials need to be provided

), view complete customs declaration data through the enterprise customs declaration query module

It is recommended that enterprises establish a three - tier risk control mechanism:

• Pre-planning:
  • Complete tax impact assessment before contract signing
  • Clarify software delivery methods and technical service proportions
• Monitoring of the matter.:
  • Consistency check between cross-border payment vouchers and contract terms
  • Regularly update the country tax policy database
• Subsequent audit:
  • Retain complete R&D cost collection records
  • Prepare transfer pricing documents for tax audits

V. Common Misconceptions in Software Export Taxation

According to customs audit cases in 2025, pay special attention to:

• Misunderstanding 1: All digital products are tax-free
  • Need to distinguish between product form and service essence
  • Some countries have started to levy digital service taxes
• Misunderstanding 2: Refund amount = input tax amount
  • Actually calculated based on FOB price × refund rate
  • Service outsourcing fees are non-deductible
• Misunderstanding 3: All R&D expenses can be additionally deducted
  • Must comply with the Pre-Tax Deduction Management Measures for R&D Expenses,
  • Overseas R&D expenses require special filing