I. AgencyExport tax refundWho is the responsible party?

According to the 2025 revised edition of theExport tax refundManagement Measures,Agency export,The business must clarify the tax rebate declaration subject:

• Agency parties holding export qualifications must sign written agency agreements with clients
• The customs declaration form must simultaneously display both the "operating unit" and the "consignor unit" as dual headers.
• New 2025 requirement: Agency parties must complete electronic agency relationship filing at the customs single window

II. What are the changes in the agency export tax rebate declaration process in 2025?

The latest declaration process includes five key steps:

• Step 1: Sign agency agreement
  • Must include goods details, tax rebate responsibility division, and foreign exchange collection terms
  • Starting from 2025, must be simultaneously uploaded to the tax filing system
• Step 2:Export customs clearanceOperated
  • Must use dual-header customs declaration forms (agency party as operating entity)
  • Added HS code intelligent verification function
• Step 3: Foreign exchange verification
  • Foreign exchange must be collected within 12 months after export (extendable to 15 months for bulk cargo)
  • Cross-border RMB settlement in 2025 is treated as foreign exchange collection
• Step 4: Tax rebate material handover
  • Agency parties must provide complete documentation to clients within 30 working days
  • New blockchain electronic invoice transmission channel
• Step 5: Tax declaration
  • The principal handles tax refund with the special invoice provided by the agent
  • The "No-Filing" Intelligent Declaration System will be implemented in 2025.

III. How to handle common issues in agency export tax rebates?

• Question 1: Can the agent directly apply for tax refund?

  According to the 2025 new policy, only two scenarios are allowed for agents to handle tax refund: self-operated export by the principal or production enterprises entrusting comprehensive foreign trade service enterprises

• Question 2: Does agency fee affect tax refund amount?

  Agency service fees should be issued separately with 6% VAT invoice and not included in FOB calculation for export goods

• Question 3: How to correct wrong customs declaration information?

  In 2025, customs will introduce a new "electronic amendment" channel, requiring corrections to be completed within 3 months after export.

• Question 4: Can tax refund still be claimed if foreign exchange cannot be collected?

  For 9 special circumstances announced by the tax authority in 2025, alternative supporting documents can be provided

IV. What materials need to be prepared for agency tax rebates in 2025?

• Basic materials:
  • Notarized agency export agreement (Chinese and English versions)
  • Electronic records of dual-header customs declaration forms
  • Copy of international transport documents
• Newly added materials:
  • Customs electronic agency relationship filing receipt
  • Blockchain VAT special invoice
  • Foreign exchange monitoring system collection certificate
• Special materials:
  • Third-party quality inspection report (for legal inspection commodities)
  • Certificate of origin declaration (applicable for preferential tariff scenarios)

V. How to avoid risks in agency export tax rebates?

Three key risk points for 2025 tax audit focus:

• Risk 1: Inconsistent four flows

  Ensure complete matching of goods flow, capital flow, document flow and information flow. Agents must maintain complete logistics tracking records

• Risk 2: Fake agency relationships

  2025 customs will verify agents actual export capacity through network checks and conduct surprise inspections on warehousing logistics systems

• Risk 3: Overdue tax refund filing

  Tax refund declaration must be completed before April VAT filing period of the following year after export, otherwise eligibility will be lost