I. What Kind ofAgency export,Is it possible to process a tax refund for the business?

According to the latest 2025 "Administrative Measures for Value-Added Tax and Consumption Tax on Export Goods and Labor Services," agentsExport tax refundThe following conditions must be met simultaneously:

• Subject Qualification Requirements:
  • The agent must possess import and export operation rights and complete the export tax refund (exemption) filing.
  • The principal shall be a general VAT taxpayer within the territory.
• Proof of Business Authenticity:
  • Sign a standardized export agency agreement (clearly specifying the entity responsible for tax refunds)
  • Complete "Four Lists and Two Tickets": Exportcustoms clearanceShipping order, bill of lading, transport document, foreign exchange receipt; VAT special invoice, export invoice

37. II. AgencyExport tax refundThe standard process includes

After the upgrade of the tax refund declaration system in 2025, the standard process will be streamlined into five steps:

• 7. Filing Stage: Submit the "Certificate of Agency for Export Goods" to the competent tax authority within 10 working days after signing the agency agreement.
• Document collection: Focus on verifying the correlation between the "domestic consignor" and "production/sales unit" fields in the customs declaration form.
• Declaration deadline: The declaration for goods exported through customs must be completed before the VAT tax filing period in April of the following year (the extended filing period in May will be abolished starting from 2025).
• Tax refund review: Pay attention to the new requirements for commodity codes under the HS intelligent verification system to be implemented by the General Administration of Customs in 2025.
• Foreign exchange exports：The deadline for foreign exchange settlement remains 12 months after the date of export, but a 3-month grace period is granted for cross-border RMB settlements.

III. What are the major risk points in agency export tax rebates?

Based on the 200+ tax refund dispute cases we have handled, the main risks are concentrated in:

• Risk of document inconsistency:
  • A discrepancy rate exceeding 3% between the product names on the customs declaration form and the VAT invoice will trigger manual review.
  • The mandatory requirement for adding "Export Contract Number" in the remarks column of newly issued invoices in 2025.
• Related-party transaction risk:
  • When there is an equity relationship between the agent and the principal, an additional explanation of price reasonableness must be submitted.
  • The recipient of payment does not match the exporter, requiring a tripartite payment agreement to be provided.

IV. What impact will the 2025 VAT credit refund policy have on export agency services?

The Ministry of Finance Announcement No. 9 of 2025 specifies two significant changes:

• Adjustment of tax refund ratio: The export tax rebate rate for manufacturing enterprises acting as agents is restored to the difference between the levy and rebate rates, while foreign trade enterprises maintain the current rebate rate.
• Enhanced digital supervision:
  • The electronic filing rate requirement for export tax rebate documentation has been raised to 90%.
  • The frequency of data exchange and verification among customs, taxation, and foreign exchange authorities has been increased.

5. How to Avoid Tax Audits on Export Tax Rebates Through Agents?

Based on the risk control solutions we have designed for Fortune 500 clients, it is recommended to focus on:

• Filing Document Management:
  • The ocean bill of lading must bear an "On Board" notation.
  • Starting from 2025, new requirements for archiving GPS data of transportation trajectories will be implemented.
• Declaration data validation:
  • The exchange rate for US dollars shall be based on the median price published by the General Administration of Customs on the third working day of each month.
  • The "Terms of Trade" on the customs declaration must logically correspond with the transport documents.

VI. What key indicators should be considered when selecting an export service agent?

Based on our 20 years of agency service experience, we recommend focusing on the following:

• Compliance Capacity:
  • Whether to have the AEO advanced certification qualification
  • Tax refund declaration approval rate in the past three years
• The response speed.:
  • Document exception handling time limit (industry standard is within 72 hours)
  • Is a 24-hour cross-border settlement channel available?