I. What type of invoice should be issued for agency import and export services?

According to the latest Administrative Measures for the Application of Zero VAT Rate for Cross - border Taxable Activities in 2025, for agency import and export services, invoices should be issued in the following two situations:

• Pure agency service fees: Issue a 6% VAT special invoice, with the remark column on the invoice clearly stating "import and export agency services".
• Agency procurement/sales business: Two types of bills need to be issued simultaneously
  • For overseas customers: Issue a Proforma Invoice
  • For domestic principals: Issue a special VAT invoice with a 13% tax rate (the enterprise must have the qualification for goods purchase and sales)

II.customs clearanceMust the amount on the bill be the same as the invoice amount?

According to Announcement No. 78 of the General Administration of Customs in 2024, there are the following three compliant operation methods:

• Declaration at FOB price: Commercial invoice amount = declaration amount + overseas freight/insurance premium
• Declaration at CIF price: The commercial invoice amount must be exactly the same as the declaration amount
• Commission listed separately: The agency service fee can be issued a 6% invoice separately and is not included in the goods declaration amount

The intelligent bill - auditing system newly launched by the customs in 2025 will focus on checking the rationality of price logic. It is recommended to declare at CIF price to minimize the inspection risk.

III. What are the special requirements for cross - border service fee invoices?

For overseas service fees generated in the import and export process (such as testing and certification, international transportation, etc.), special attention should be paid to:

• Invoice for advance - paid expenses: It is required to provide a proforma invoice + payment voucher issued by an overseas institutionForeign exchange verification requirementsOriginal Copy
• : For service fees of more than $50,000 per transaction, the contract filing number should be marked in the remarks column of the invoiceTax deduction voucher
• : Overseas invoices need to be attached with a translation and certification document issued by a professional institutionbefore they can be recorded in the accountsAccording to the case database for inspection by the State Taxation Administration in 2025high - frequency errors include:

IV. What invoice errors will lead to the failure of tax rebates?

According to the State Taxation Administration in 2025Export tax refundThe verification case database shows that high - frequency errors include:

• The invoice title is inconsistent: The business entity on the customs declaration form does not match the name of the purchaser on the VAT invoice
• Confusion of measurement units: The customs declaration uses "kilograms," while the invoice uses "pieces" without specifying the conversion ratio.
• Incorrect exchange rate conversion: The exchange rate on the 1st of the current month deviates from the actual exchange settlement rate by more than 2%
• Missing related vouchers: The agency agreement was not submitted for filing simultaneously with the invoice

V. Application Specifications of Electronic invoices in import and export businesses

According to the Administrative Measures for the Cross - border Use of Electronic Invoices implemented on March, 2025:

• Domestic transactions: It is necessary to use VAT electronic special invoices (OFD format)
• Cross - border payments and receipts: The use of PDF - format electronic invoices is allowed, but it must meet the following requirements:
  • Include the digital signatures of both the buyer and the seller
  • Show the transaction currency and exchange rate
  • Attach SWIFT remittance route information

Special reminder: In case of the mixed use of paper invoices and electronic invoices, a special note must be made in the tax filing system.

VI. How to avoid trade disputes caused by invoices?

Based on 20 years of practical experience, it is recommended to take the following measures:

• Triple - check mechanism: The business, finance, and customs departments check the invoice elements
• Version control: Indicate the invoice version number and revision date (such as INV2025 - 001 - R2)
• Dispute clauses: Clearly specified in the agency agreement
  • Liability attribution for invoice errors
  • Time limit for re - issuing invoices
  • Handling method for exchange rate fluctuations