I. Who exactly issues the invoice for entrusted export agency?

According to Announcement No. 12 of the State Taxation Administration in 2023 and the current operational guidelines, there are two invoicing models for entrusted export agency:

• Mode One：As the service provider, the agency company issues a proforma invoice directly to the overseas buyer on behalf of the actual exporter (the principal).
• Mode 2: After the agency company purchases and takes ownership of the goods for self-export, it must issue a special VAT invoice to the client.

In actual business operations in 2025, approximately 78% of foreign trade enterprises adopted Model 1. Special attention must be paid to explicitly stipulating the invoicing entity in the agency agreement to avoid subsequent tax disputes.

2. Should the invoice be issued under the name of the agent or the principal?

The invoice title must be filled in according to the following guidelines:The "subject-verb agreement" rule(Contract, Invoice,customs clearanceSingle):

• When the agency company acts as the "consignor" on the customs declaration form, the invoice header should display the full name of the agency company.
• The "Actual Supplier: XXX Company" (i.e., the consignor) must be clearly stated in the remarks column of the invoice.
• 16. Special circumstances:
  • Enterprises in the Cross-border E-commerce Comprehensive Pilot Zone may apply for direct invoicing by the consignor.
  • Processing trade enterprises are required to additionally provide the customs manual number.

III. How to Determine the Amount on Export Invoices to Ensure Compliance?

It is recommended to followFOB priceWhen determining the invoice amount, please note:

• The agency service fee shall be invoiced separately with a 6% VAT invoice (not to be included in the goods value).
• New regulations from the State Administration of Foreign Exchange in 2025 require:
  • Export transactions exceeding $50,000 require the submission of a bank foreign exchange receipt slip.
  • Cross-border RMB settlement requires the marking of the "CIPS" clearing code.
• Common Misconceptions Warning:
  • It is not allowed to directly use the tax-included purchase price for invoicing.
  • Avoid mixing agency commissions into the cargo value amount.

IV. How to determine the timing of invoice issuance?

It is recommended to proceed according to the following timeline:

• 3 working days before customs declaration: Confirm the proforma invoice.
• Within 5 working days after shipment: Issue a formal commercial invoice.
• Within 10 working days after receiving the payment: complete the issuance of the special invoice for tax refund.

Special reminder: The e-invoice system for 2025 has achieved data integration with the Single Window. It is recommended to adopt it.Blockchain Electronic InvoiceImprove efficiency.

V. Warning on Common Invoice Error Cases

• Case 1: A garment factory failed to receive a tax refund of 230,000 yuan due to a discrepancy between the invoice title and the consignor on the customs declaration form.
• Case 2: The machinery exporter included ocean freight in the invoice amount and was subsequently required to pay back taxes of 180,000 yuan by customs.
• Case 3: Using an obsolete invoice supervision seal format, resulting in document return delays and missed shipping schedules.

VI. Professional Recommendations: Key Compliance Operation Points for 2025

• , which records complete information for each expenditure in real time: service content, execution progress, invoice status, tax treatment, etc.Foreign Exchange Management Class A QualificationPayment documentation
• It is explicitly stipulated in the agency agreement:
  • Invoice Types and Issuance Time Limits
  • Data Modification Authorization Terms
  • Dispute resolution mechanism
• Establish monthlyThree-document verificationMechanism (contract, invoice, customs declaration)
• The retention period for important vouchers has been extended to 10 years (as per the new Tax Collection and Administration Law effective in 2025).