Agency export,Can it really handle tax rebates?

According to the latest Announcement on the Policies of Value - added Tax and Consumption Tax on Exported Goods and Services in 2025, the tax - rebate eligibility under the agency export model needs to meet three core conditions:

• 28. The goods actually leave the country: The export goods declaration form (electronic data) issued by the customs needs to be provided
• Foreign exchange receipt verification: Cross - border RMB or foreign exchange settlement needs to be completed
• Complete value - added tax chain: The manufacturing enterprise needs to obtain an input invoice, and the foreign trade enterprise needs to obtain a special purchase invoice

Which agency export models can apply for tax rebates?

In 2025, the State Taxation Administration clearly defined two compliant agency models:

• Treated as self - operated exportsMode:
  • The trustee (agency company) acts as the tax - rebate subject
  • A Agency Export Agreement needs to be signed and filed
  • The agency company is required to have the right to operate import and export
• Agent for tax rebateMode:
  • The principal (manufacturing enterprise) acts as the tax - rebate subject
  • A Agent for Tax Rebate Agreement needs to be signed and tax registration completed
  • The manufacturing enterprise must be a Class I or Class II export enterprise

AgentlyExport tax refundWhat materials need to be prepared?

The new tax - rebate declaration system in 2025 requires the submission of:

• Export declaration form stamped with the customs inspection seal
• Certificate of agency export goods (original)
• Deduction voucher of special value - added tax invoice (for foreign trade enterprises)
• Foreign exchange receipt slip or cross - border RMB settlement voucher
• Registration Receipt of Agency Agreement (Searchable in Tax System)

How to Avoid AgencyExport tax refundRisks?

Based on a case in 2023 where a listed company was punished for illegal agency tax refund, special attention should be paid to:

• Verification of the Qualifications of the Agent:
  • Check the AEO Certification Level of the Agency Company by the Customs
  • Confirm that the Tax Credit Rating is not lower than Level B
• Monitoring of Capital Flow:
  • The foreign exchange collection account must be consistent with the agreement in the agency agreement
  • Eliminate the situation of third - party collection of payment for goods
• Management of Document Timeliness:
  • The customs declaration form must be obtained within 90 days after export
  • The tax refund declaration shall not exceed April 30th of the year following the export

What situations will lead to the inability to handle tax rebates for agency exports?

Based on the recent joint inspection cases by the General Administration of Customs and the State Taxation Administration, special attention should be paid to:

• The goods actually do not leave the country (such as one - day tour in the bonded area)
• The export commodity code does not match the product name on the VAT invoice
• The difference between the foreign exchange receipt amount and the declared customs amount exceeds 5%
• Agency company included in tax violation 'blacklist'
• Cross - year declaration (for example, exports in 2025 need to be declared before April 2026)

It is recommended that foreign trade enterprises, when choosing agency export services, give priority to those withQualifications of Class - I Export EnterprisesandAdvanced Certification by the CustomsandTax Credit Level Aprofessional agency companies. For special trade methods (such as cross - border e - commerce, market procurement), it is recommended to consult the special management department of the customs separately to obtain the latest policy guidance.