I. AgencyExport tax refundWhat are the main risks that may be faced?

In the latest foreign trade practices in 2025, the following risks mainly exist in agency export tax rebates:

• Qualification risks: Some agency companies lack real export qualifications and operate through affiliated methods
• Document risk:customs clearanceInconsistent 'three documents' information: invoice, VAT invoice, forex receipt
• Funding risk: The extension of the tax rebate cycle leads to the occupation of funds, and some agents misappropriate the tax rebate funds
• Time - limit risk: In 2024, the intelligent audit system upgraded by the State Taxation Administration has more stringent requirements for the timeliness of documents
• Legal risks: Joint liability for being involved in criminal cases such as false issuance of value - added tax invoices

Typical case: In 2023, a clothing enterprise exported through an informal agent. Due to the inflated value of the goods on the customs declaration form, it was inspected by the customs. Not only was the tax rebate recovered, but it also faced a fine of 30% of the value of the goods.

How to identify the true qualifications of an agency company?

It is recommended to verify the agency qualifications through the following methods:

• Inspect 'three certificates' originals:
  • The record receipt of the consignor and consignee of import and export goods of the customs
  • SAFE (State Administration of Foreign Exchange) registration certificate
  • Electronic Port IC Card
• Query filing information via 'China Customs Enterprise Import/Export Credit Information Platform'
• Request to provide tax rebate declaration records and bank account entry vouchers for the past two years

What key points should be noted for document compliance?

According to the latest tax rebate policy in 2025, focus on controlling:

• Time matchingThe date on the customs declaration form and the date of issuing the VAT invoice should be within 3 months.
• Consistency of cargo valueThe difference between the contract amount and the amount on the customs declaration form shall not exceed ±5%.
• Logistics voucherComplete copies of the ocean bill of lading/air waybill must be retained.
• Proof of foreign exchange receiptThe bank exchange memo must indicate the corresponding customs declaration number.

Special reminder: Since July, 2024, the State Taxation Administration requires that all tax refund declarations must be uploaded.Digital signatureThe electronic version of the contract.

How to ensure capital safety?

It is recommended to adopt the following risk - control measures:

• Set up a joint management account: The tax refund amount directly enters the jointly supervised account of both parties.
• Agree on the settlement cycle: It is specified that the distribution should be completed within 3 working days after the tax refund arrives.
• Purchase credit insurance: The agency tax refund performance insurance launched by China Export & Credit Insurance Corporation can cover 80% of the risks.
• Operate in batches: The amount of a single business shall not exceed 20% of the registered capital of the agency company.

How to effectively safeguard rights in case of tax rebate disputes?

It is recommended to handle it according to the following steps:

• Step 1: Fix electronic evidence
  • Save complete email communication records
  • Export instant messaging records such as WeChat/DingTalk
• Step 2: Apply for the retrieval of customs data
  • Download the original customs declaration data through the electronic port
• Step 3: Initiate legal procedures
  • Apply to the International Trade Arbitration Commission for commercial arbitration
  • Report to the economic investigation department in case of criminal offenses

How to choose between self - handling tax rebates and agency tax rebates for enterprises?

Conduct a comparative analysis from three dimensions:

• Cost comparison:
  • Self - built team: The average annual cost is about 250,000 yuan (including personnel, systems, and training).
  • Agency service: Usually charged at 1.2% - 2% of the tax refund amount.
• Time - efficiency comparison:
  • The average tax refund cycle of professional agencies is 45 days.
  • New enterprises generally take more than 90 days to operate on their own.
• Risk Comparison:
  • The agency model shifts the compliance risk of documents
  • Self - operation assumes all legal responsibilities

VII. What are the new changes in the tax refund policy in 2025?

Three new policies worthy of attention:

• Cross - border e - commerce B2B exports applying the market procurement trade method for customs declaration can enjoy tax rebates
• Green channels for tax rebate review of strategic emerging industries such as biomedicine and new energy
• Establish a national unified export tax rebate risk early warning indicator system (ETRS)