Agency export,Must Special Invoices Be Issued by the Agent?

According to the current [2025]Export goodsValue-added Tax and Consumption Tax Management Measures for Labor Services, in agent export business:

• When the "Domestic Consignor" field on the customs declaration form displays the name of the agency company, a special invoice must be issued by the agent.
• The invoice remarks column must indicate'Agency Export'wording and consignor taxpayer identification number
• The invoice amount should be consistent with the customs declaration amount and foreign exchange receipt amount (three-document consistency)

Should the Invoice Header Show the Principal or the Agent?

Handling should be based on the actual business situation:

• Entrusted agency model
  • Seller Field: Fill in the principals full name and tax ID
  • Buyer Field: Fill in the overseas customer information
• Purchase-Sale Agency Model
  • Seller section: Fill in the agent company information
  • Buyer Field: Fill in the overseas customer information

What Additional Information is Required for the 2025 New Version Invoice?

According to Announcement No. 45 issued by the State Taxation Administration in December 2024:

• Must be filled in13-digit customs declaration number(The original 11-digit format has been abolished)
• Cross-border RMB settlement must be marked withCIPSIdentification code
• Blockchain invoices must displayHash value verification portal

What is the Fundamental Difference Between Agent Export Invoices and Proforma Invoices?

There are significant differences in function and legal effect between:

• Legal effect
  • Special invoice: Legal VAT deduction document
  • Proforma invoice: Commercial agreement document with no tax validity
• Issuance time
  • Special invoice: Must be issued within 15 days after goods departure
  • Proforma invoice: Can be issued at contract signing

How to Avoid Tax Refund Risks Caused by Agent Export Invoices?

Combined with typical cases recently published by the General Administration of Customs, it is recommended to pay attention to:

• Four-stream consistency verification
  • Goods flow (customs declaration form)
  • Fund flow (Payment receipt)
  • Invoice flow (special invoice)
  • Contract flow (agency agreement)
• Special business processing
  • Entrepot trade requires attachment ofWarehouse receipt delivery proof
  • Cross-border e-commerce must be marked withCustoms supervision code