
1. What is the underlying logic for recognizing agency export revenue?
According toAccounting Standards for Business Enterprises No. 14 - RevenueThe recognition of agency export revenue must simultaneously satisfy three core requirements:Transferencia de controlandMeasurabilityandCommercial substance。Under the agency export model, the service provider (agent) needs to pay special attention to:
- Revenue recognition is limited to the agency service fee portion only.
- Ownership of the goods shall always remain with the principal.
- customs clearanceThe display of agent information in the "Business Unit" column does not affect the nature of income.
II. What are the key changes in the latest tax regulations for 2025?
In accordance with the announcement issued by the State Taxation Administration in 2023,,Export goods"Management Measures for Value-Added Tax and Consumption Tax on Labor Services", Special attention should be paid to the agency export business:
- VAT filing deadline:
- If the documents are not fully collected within 60 days after the goods leave the country, they shall be treated as domestic sales.
- The deadline for foreign exchange receipt is extended to the tax filing period of April in the following year.
- Income Tax Recognition Rules:
- Adopt the accrual basis principle.
- Foreign exchange income can only be confirmed after actual receipt of payment.
III. How to Grasp the Five Key Confirmation Points in Practical Operations?
Based on our hands-on experience serving 300+ foreign trade enterprises, we recommend focusing on the following key nodes:
- Date of Bill of Lading Issuance: Preliminary proof of fulfillment of delivery obligations
- Customs declaration release date: Legal proof of the actual departure of goods
- Foreign exchange verification date: Official confirmation of payment receipt completion
- Customer sign-off date: Applicable to CIF/DDP and other collect terms
- Service Acceptance Form Signing Date: Direct evidence of proxy service completion
IV. Three Common Cognitive Misconceptions in Enterprises
We have noticed that many foreign trade enterprises hold the following misconceptions:
- Misconception 1: Taking the receipt of payment from the client as the confirmation point.
- The actual benchmark should be based on the completion of agency services.
- Misconception 2: Confusing the Timing of Accounting Recognition with VAT Declaration
- Value-added tax is calculated based on the customs declaration date, while accounting revenue is recognized according to the progress of service completion.
- Misconception 3: Neglecting the Impact of International Trade Terms
- The timing of risk transfer differs between FOB and CIF terms.
V. Professional Advice: How to Establish a Compliance Verification Mechanism?
We recommend that enterprises establish the following standardized processes:
- Clearly stipulate the service completion criteria in the agency agreement.
- EstablishedFour-document matchingSystem (contract, bill of lading, customs declaration form, foreign exchange receipt)
- Conduct monthly.Estimated Revenue Adjustment
- Configure using the ERP systemTriple confirmation node:
- Logistics Confirmation (Cargo Departure)
- Document confirmation (customs clearance completed)
- Fund Confirmation (Foreign Exchange Receipt)
VI. Guidelines for Handling Special Circumstances
For complex business scenarios, special attention should be paid to:
- Transit trade: withDate of secondary customs declaration completionFor the record
- Cross-border e-commerce: According toSettlement cycle of payment platformconfirmed
- Countries with foreign exchange controls: AdoptBarter Trade Confirmation Rules
- Long-term Agency Contract: ByRecognition of Performance Progress by Stages
(Note: The professional opinions expressed herein are based on publicly available regulations and industry practices. For specific operations, please refer to the latest interpretations by the competent tax authorities. It is recommended to consult professional trade advisors before engaging in significant transactions.)