I.Agency export,Who exactly handles the tax refund?

According to the 2025 Value-added Tax Management Measures for Cross-border Taxable Activities, agencyExport tax refundentities must meet three conditions:

• Actual goods ownership party: Must hold supporting documents such as sales contracts and fund flow records
• Complete value - added tax chain: The principal must issue special VAT invoices to the agent
• Foreign exchange settlement documents: Foreign exchange must be settled through the agents account or provide a tripartite foreign exchange collection agreement

A cross-border e-commerce company in 2024 had 1.2 million tax refunds stranded due to unclear tax refund entity in the agency agreement, serving as a warning about the importance of agreement clauses.

37. II. AgencyExport tax refundWhat documents need to be prepared?

The 2025 new version of the declaration system requires:

• Basic documents:
  • customs clearanceForm (the declaration unit column must indicate agency relationship)
  • VAT special invoice (with the remark "agency export" noted in the remarks column)
  • Foreign exchange receipt documents (exchange settlement slip or cross-border RMB payment receipt)
• Special documents:
  • Notarized copy of agency agreement (mandatory for cross-border agency)
  • Proof of goods ownership transfer (necessary document for bulk commodity transactions)

III. Can small-scale taxpayers claim tax refunds through agency exports?

Under current policies, small-scale taxpayers export goods are eligible for tax exemption, but when using agency exports, note:

• If the agent is a general taxpayer, it may involve input tax transfer
• In special circumstances, applications can be made to issue special VAT invoices on behalf, requiring:
  • Single transaction amount exceeding 500,000 yuan
  • Provision of tax payment certificates
  • Application through electronic tax bureau

IV. What changes have occurred in agency export tax refund declaration deadlines?

New regulations implemented from 2025 require:

• Foreign exchange collection deadline: Within 12 months from customs declaration date
• Declaration deadline: By the 15th of the month following foreign exchange collection
• Special circumstance extensions:
  • Force majeure factors may extend for 6 months
  • Forward exchange collection requires prior filing

V. How to prevent the risks of agency export tax rebate?

Recommend adopting a three-tier prevention and control system:

• Pre-event review:
  • Verify the export tax rebate (exemption) filing status of the agent
  • Check the agents customs AEO certification level
• During - event monitoring:
  • Monthly verification of customs declarations against foreign exchange collection data
  • Track tax rebate progress (now available for real-time query via electronic port)
• Post-event audit:
  • Retain full set of documents for at least 10 years
  • Annual special tax audit

VI. What special requirements apply to cross-border e-commerce agency exports?

For export business under regulatory codes 9710/9810:

• Must use the cross-border e-commerce comprehensive pilot zone online integrated service platform
• Need to provide:
  • Platform transaction screenshots (including order number, payment information)
  • Logistics information comparison report
• Tax rebate ratio calculated based on actual transaction amount (deducting platform commissions)

VII. How to avoid tax risks when converting agency exports to domestic sales?

For returned goods or domestic sales conversion, the following must be processed:

• Export goods return tax reimbursement certificate
• Input tax amount transfer calculation:
  • Calculate transfer amount based on original tax rebate rate
  • For goods subject to consumption tax, simultaneous supplementary payment is required

VIII. How does foreign exchange control affect agency export tax refunds?

Key points of 2025 foreign exchange management new policy:

• The agent receiving foreign exchange must be marked as "export on behalf of" at the bank.
• Cross-border RMB settlement:
  • Provide CIPS system transaction number
  • Settlement bank must have cross-border RMB business qualification

IX. How to select compliant agency export service providers?

Recommend verifying seven qualifications:

• Customs AEO Advanced Certification
• Class A enterprise in foreign exchange income and expenditure directory
• First-class export tax rebate enterprise qualification
• Electronic port IC card authorization records
• Export credit insurance records
• No record of tax administrative penalties
• Bank credit line certificate

X. How to resolve agency export tax refund disputes?

Recommend adopting a four-step processing method:

• Step 1: Collect complete evidence chain (logistics, capital flow, document flow)
• Step 2: Apply for tax administrative reconsideration (must be filed within 60 days)
• Step 3: Engage professional tax lawyer
• Step 4: File administrative lawsuit if necessary (note 3-year statute of limitations)