1. Does the export-to-agent model require re-registration for foreign exchange management filing?

According to the latest 2025 "Guidelines on Foreign Exchange Administration for Trade in Goods," when an enterprise converts self-operated exports intoAgency export,Time:

• The foreign exchange directory registration must be changed.: Within 30 days after the business change, submit the "Application for Change of Foreign Exchange Receipts and Payments Enterprise Directory" to the local foreign exchange bureau.
• Please provide the original copy of the agency agreement along with the following documents:
  • Termination Certificate of Original Export Contract
  • Explanation of Key Terms in the New Agency Agreement (Clarification of Payment Responsibilities Required)
  • Change Record of Customs Supervision Mode

2. What are the special requirements for foreign exchange receipts and payments under the agency model?

The State Administration of Foreign Exchange implements a thorough regulatory approach towards agency export collection and settlement, and enterprises should note:

• Foreign Exchange Receipt Account Management:
  • The proxy's account pending verification must be used.
  • The foreign exchange receipt declaration must be marked with the phrase "Agency Export."
• Requirements for Foreign Exchange Settlement Materials:
  • Copy of the agency agreement (for each transaction)
  • Official Receipt Confirmation Letter with Company Seal
  • Bank Special Business Processing Form

Third,Export tax refundHow to handle the change of subject?

According to Announcement No. 18 of 2025 issued by the State Taxation Administration:

• Process for Changing the Subject of Tax Refund:
  • The export tax refund (exemption) filing change needs to be processed.
  • Submit the electronic data of the "Certificate of Agency Export Goods".
  • The original enterprise needs to complete the write-off of historical business.
• Key Risk Warnings:
  • La "persona expedidora nacional" y la "unidad de producción y venta" en la declaración de aduanas deben coincidir.
  • The agency agreement must clearly stipulate the terms of ownership transfer of the goods.

IV. Common Operational Missteps and Compliance Recommendations

• Typical Violation Scenarios:
  • Continue using the original enterprise foreign exchange account for receiving payments.
  • Failure to complete the record change filing as required by regulations.
  • The agency agreement lacks key liability clauses.
• Professional Operation Recommendations:
  • Notify the agent to connect with the documentation system 60 days in advance.
  • Establish a three-party reconciliation mechanism (enterprise-agent-bank)
  • Quarterly verification of foreign exchange monitoring system data

V. How to Choose a Compliant Proxy Service Provider?

15. It is recommended to evaluate agency qualifications from the following dimensions:

• Foreign exchange classification level (Priority for Class A enterprises)
• Customs AEO certification status
• Capability of Electronic port data docking
• Historical Tax Audit Records
• Whether trade compliance specialists are assigned