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

According to the Administrative Measures for Value-Added Tax and Consumption Tax on Export Goods and Labor, under the agency export model, the tax refund entity is always the actual owner of the goods.The entity eligible for tax refund is always the actual owner of the goods:

• The agent is only responsible for customs clearance and foreign exchange collection procedures
• The principal shall declare independently with supporting documents such as agency agreement and VAT special invoice
• New requirement for 2025: Agency contracts must clearly indicate the term "export agency."

37. II. AgencyExport tax refundWhat core documents are needed?

List of tax refund declaration materials for 2025 includes:

• Basic documents:
  • Original agency agreement with official seal
  • Customs declaration form for export goods (tax rebate copy)
  • Special VAT invoice (deduction voucher).
• Newly added materials:
  • Bank foreign exchange receipt (must match customs declaration amount)
  • Logistics tracking proof (ocean bill of lading/air waybill)
  • Mandatory requirement starting 2025: Upload electronic version of agency agreement for record

III. What Are the Time Limits for Agency Export Tax Refund Declarations?

Pay special attention to three key time nodes:

• Collect all documents within 90 days after customs export
• Complete declaration during VAT tax filing period in April of the year following goods departure
• 2025 foreign exchange new policy: Collection time limit shortened from 9 months to 6 months (except for bulk commodities)

IV. What Are the Common Tax Refund Risks in the Agency Export Model?

According to customs data statistics from recent three years, among failed cases of agency export tax refund:

• 43% caused by inconsistent document information
  • Discrepancy between customs declaration and invoice product names/quantities
  • The difference between the amount of foreign exchange received and the declared amount exceeds 5%.
• 29% related to agent qualification issues
  • Agent enterprise included in dishonesty list
  • Missing import/export business scopeExport agentQualified

I. What kind of enterprises can engage in export agency business?

Recommended evaluation dimensions for agency enterprises:

• Verify enterprise credit:
  • China Customs AEO certification status
  • the classification level of the State Administration of Foreign Exchange
• Review business capabilities:
  • Whether equipped with professional foreign trade document specialists
  • Whether has experience handling cross-customs zone declarations
• Key notice for 2025: Require service providers to offer electronic port data interface capability