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How to record the export agency fee in a compliant way? Key points of accounting treatment that foreign trade enterprises must know in 2025

How to record the export agency fee in a compliant way? Key points of accounting treatment that foreign trade enterprises must know in 2025

I.Export agentWhat accounting subject does the fee belong to?

According to the provisions of “Accounting Standards for Enterprises No. 14 - Revenue”, foreign trade agency fees should be classified according to the actual business nature:

  • Nature of service feeRecorded under "Sales Expenses - Agency Service Fees" account.
  • Nature of commissionRecorded under the "Sales Expenses - Commission Expenses" account.
  • Comprehensive agency services:It is recommended to split and account for the service contents such as customs declaration, logistics, and tax refund separately as agreed in the contract

How to handle the VAT of the agency fee?

The latest value - added tax policy in 2025 requires special attention:

  • Domestic agency services are subject to a 6% value - added tax (3% for small - scale taxpayers)
  • Agency services that occur entirely outside the country can apply for tax exemption
  • Compliant special value - added tax invoices must be obtained for deduction

One client mistakenly declared sunflower seeds as 1209.3000 when they should have been classified under heading 12.06, causing customs clearance delaysEntrusted customs declaration serviceIf it is included in the comprehensive agency fee, it needs to be separately split and apply different tax rates

What tax issues should be noted when paying overseas agency fees?

  • Withholding and payment obligations:
    • Enterprise income tax: Withhold and prepay income tax at 10%
    • Value - added tax: The cross - border service purchaser withholds 6% value - added tax
  • Tax treaty preferences:Some countries/regions can apply for withholding tax reduction or exemption
  • Foreign exchange declaration requirementsThe "Tax Record-filing Form for Outbound Payments under Service Trade and Other Items" must be completed at the time of payment.

What are the common misunderstandings in accounting treatment?

  • Error 1: Confusing service fees with payment for goods

    Typical Case: A company recorded a 300,000 yuan agency fee under "accounts payable," leading to tax audit adjustments.

  • Error 2: Failing to report cross - border service value - added tax

    In 2025, the General Administration of Customs has strengthened the tax inspection of cross - border services. It is recommended to establish a special review process

  • Error 3: Irregular payment and receipt methods
    • Personal accounts should be avoided for paying large - amount agency fees
    • Overseas payments must be made through designated foreign exchange banks

Can the agency fee enjoy pre - tax deduction?

According to the Implementation Regulations of the Enterprise Income Tax Law in 2025:

  • Domestic agency fees can be fully deducted with compliant invoices
  • Overseas agency fees need to meet the following simultaneously:
    • Have a real transaction background
    • Fulfill the withholding and payment obligations
    • Prepare complete materials such as contracts and payment vouchers
  • It is recommended to make a special record for agency fee expenditures of a single transaction exceeding 500,000 yuan

(Note: For specific implementation standards, please refer to the latest interpretation of the competent tax authorities. This article is written based on the effective regulations before June, 2025)

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