一、代理輸出What are the basic requirements for tax exemption?

According to the latest 2025輸出稅還付Policy: For an enterprise to enjoy tax exemption through export via an agent, it must simultaneously meet three core conditions:

• Proof of Genuine Trade Relationship: A notarized agency agreement, purchase and sale contract for the goods, and logistics documents must be provided.
• Export Qualification Requirements: The agent must possess import and export rights and complete customs registration.
• Foreign exchange receipt and payment voucher: Provide a bank foreign-exchange settlement slip or a cross-border RMB receipt/payment certificate

II. How many steps are involved in the specific operational procedure for tax-exempt declaration?

2025年に稅関総署が導入する「シングルウィンドウ」3.0システムの下では、代理輸出免稅申告の手続きは以下のように簡素化されている：

• Step 1: Sign the tripartite agreement
  • Manufacturers, foreign trade agents, and overseas purchasers clearly define their rights and obligations.
• Step 2: Filing and Registration
• The agent must complete the tax filing 15 working days before the goods are exported.
• Step 3: Customs Declaration
  • 「ダブルヘッダー」通関申告書（製造元＋代理店）を使用する

III. Under what circumstances might a tax-exemption application be rejected?

Based on the 2024 customs audit cases, special attention should be paid to the following situations:

• Conflict in documentation timelines: The date of the agency agreement is later than the production date of the goods
• Abnormal fluctuations in cargo value: Unit price variance for the same category of goods exceeds the industry standard by 15%.
• Violation of the inward remittance route: Overseas payments are remitted directly to the manufacturing enterprise's account

IV. How to guard against tax risks in export agency arrangements?

「三位一體」のリスク管理措置を採用することを推奨します：

• Qualification Review Mechanism: Update the agent's customs credit rating report quarterly
• Traceable process management: Use blockchain technology to store evidence of critical operational nodes
• Professional audit support: Engage a Class-A tax firm to conduct quarterly compliance reviews

V. What are the new policy changes for export agency in 2025?

The Announcement on Improving the Administration of Export Tax Refund (Exemption) for Foreign Trade Integrated Service Enterprises, issued by the Ministry of Finance in January 2025, makes it clear:

• Electronic filing system reform: Abolish paper filing forms and implement customs electronic seal filing.
• Shorter declaration deadline: The post-export declaration deadline has been adjusted from 90 days to 60 days
• Negative List Management: Addition of 3 categories of goods prohibited for export by proxy (see GACC Circular No. 23 of 2025 for details)

Special Reminder: The “Cross-Border Trade Services Administration Measures” that take effect in April 2025 require export agents to purchase professional liability insurance; when selecting a partner, it is recommended to verify whether the policy’s coverage includes joint tax liability.