I.Agency export,Who owns the companys tax rebate right?

According to the latest 2025 Administrative Measures for VAT and Consumption Tax on Export Goods and Services, three points need attention regarding tax rebate right ownership:

• Nominal tax rebate entity：The agency company, as the "consignor" on the export declaration form, is eligible for tax refund declaration.
• Actual rights ownership: It must be clearly stipulated in a written agreement. It is recommended to adopt the combination of a "trustee agency agreement + tax refund right transfer declaration."
• Fund flow path: After the tax rebate is received, the agency company should transfer the amount (after deducting agreed fees) to the principal within 5 working days

How to calculate agency service fees reasonably?

The mainstream fee models in the 2025 market include:

• Fixed percentage system: Charge 0.8%-1.5% of the tax rebate amount (depending on product complexity)
• Graded rate system:
  • Annual export amount < 5 million yuan: 1.2%
  • 5-20 million yuan: 0.9%
  • ＞20 million yuan: 0.6%
• Comprehensive service package: Includes full-process services for customs clearance, logistics, and tax refund (annual fee system)

Special Notice: The "Guidelines on Cross-Border Trade Service Charges" issued by the Ministry of Finance in 2024 explicitly prohibit "refund-amount-linked charges." In practice, it is essential to ensure compliance by properly structuring the fee arrangements.

How to handle VAT special invoices most safely?

Key points for VAT input processing under export agency model:

• Invoice flow direction: Suppliers should issue invoices to the actual exporting enterprise, not the agency company
• Certification timeframe: Must be completed within 180 days from the invoice date (certification period remains unchanged for 2025)
• Three - flow integration: Goods flow, fund flow, and document flow must match the actual transaction. Special attention:
  • Agency companies cannot be listed as invoice recipients
  • Payment documents must display the principals account information

How to allocate responsibility for delayed tax rebate payments?

Based on analysis of typical dispute cases from the past three years, liability allocation rules:

• Documentation issues: Agency companies are not liable for delays caused by documentation errors provided by the principal
• Declaration issues: Agency companies must compensate for interest losses caused by operational errors (calculated according to LPR)
• Policy changes: Newly added semiconductor in 2025Export tax refundreview process, both parties should share risks

It is recommended to stipulate in the agreement: Additional compliance costs arising from policy adjustments shall be allocated based on actual occurrence.

How to ensure transparency in the tax rebate allocation process?

Enterprises are advised to require agency companies to implement the following supervision measures:

• Electronic tracking system: Real-time viewing of tax refund progress (full process from declaration to account crediting)
• Dual-account management: Special tax refund accounts require the principals reserved seal
• Regular reconciliation mechanism: Provide official-stamped Tax Refund Detailed Statement before the 10th of each month
• Abnormal early warningTax refunds outstanding for over 90 days will automatically trigger special audits