I.Agency export,Under this model, who exactly is the entity eligible for tax refunds?

According to the 2025 revised edition of theExport goodsThe Measures for the Administration of Value-Added Tax and Consumption Tax on Labor Services stipulate that export agency business shall implement"Who operates, who declares"Principle:

• An export-licensed agency company acts as the operating entity for customs declaration and export.
• The actual cargo owner (the principal), acting as the production/sales entity, applies for the tax rebate.
• Handling in special circumstances:
  • When a manufacturing enterprise entrusts a comprehensive foreign-trade service enterprise to handle its exports, the "tax-rebate agency" model applies.
  • Cross-border e-commerce B2B exports are now subject to the new "list-based release and consolidated declaration" rule

II. What core documents need to be prepared for the tax refund process?

In 2025, the General Administration of Customs will implement an electronic document filing system, but the following materials still require special attention:

• Basic materials:
  • Export Agency Certificate for Goods, endorsed and stamped by the tax authority (electronic version must include a digital signature)
  • VAT Special Invoice Deduction Copy (must be verified through the State Taxation Administration Invoice Verification Platform)
• Key Documents:
  • Customs Declaration Foreign Exchange Verification Copy (with the newly added electronic seal of the State Administration of Foreign Exchange starting from 2025)
  • The transport document must specify the actual consignee's information.

III. What factors affect the tax refund cycle?

According to service case statistics from the past three years, the standard tax refund cycle is approximately 45–90 days. The main causes of delay include:

• Delay due to documentation issues:
  • The product names and units on the customs declaration do not match those on the VAT invoice (special attention is required due to the 2025 customs HS code update).
  • Foreign exchange verification amount discrepancy exceeds 5%
• Policy factors:
  • 2025 Key Monitored Commodities List adds categories such as photovoltaic modules and lithium batteries
  • Class-A export enterprises can enjoy a 5-working-day expedited tax refund channel.

IV. How to prevent agency fraudExport tax refundRisks?

Based on the 2025 Supreme People's Court model cases, the following risk-control measures are recommended:

• The contract terms clearly state:
  • Agreed Customs Declaration Filling Standards (especially regarding trade mode and transaction mode)
  • Clearly define the deadline for document transmission and the liability for breach of contract
• Key Points for Process Monitoring:
  • Require the agent to provide real-time customs release information.
  • Log in to the e-Port regularly to verify customs declaration data

1V. V. What are the important changes in 2025s tax refund policies?

• Digital Transformation:
  • Fully implement "paperless export tax rebate filing" (the originally required 15 paper documents have been reduced to 3).
  • Direct connection between customs and tax data enables cross-departmental automatic verification
• Enhanced supervision:
  • Establish a traceability system for export goods (including data on raw material sourcing and production energy consumption)
  • Implement differentiated export tax rebate verification for RCEP member countries

6. What qualifications should be noted when selecting an agency?

It is recommended to focus on verifying:

• The basic qualifications:
  • Customs AEO Certified Enterprises (Priority for Advanced Certification)
  • Class A Enterprise Qualification of the State Administration of Foreign Exchange
• The Professional Capacity:
  • Whether it is staffed with professionals such as International Trade Compliance Managers (ICC)
  • No record of major administrative penalties in the past three years (verifiable via the official Credit China website).