Can Tax Refunds Be Claimed Under Agency Export?

According toThe latest announcement of the State Taxation Administration for 2025,under the agency export modelthe actual supplier (entrusting party)is eligible for tax refund benefits.The agency company,as the entrusted party,must submit the Agency Export Goods Certificate to the tax authorities and assist the entrusting party in completing foreign exchange verification and VAT special invoices,among other tax refund requirements.It is worth noting that the agency company itselfcannot claim tax refunds,but it must fulfill legal obligations such as customs declaration record-keeping and document circulation.

What Conditions Affect AgencySuccess Rate?

The implementation of the plan in 2025General Administration of Customs Order No.38Explicitly requires that agency export tax refunds must simultaneously meet:

• Completedocumentchain
  • Agencyagreement(mustspecifytheresponsibleentityfortaxrefund)
  • VATspecialinvoice(productnameandquantitymustexactlymatchthecustomsdeclaration)
  • Supportingdocuments(foreignexchangeadministrationverificationrecords)
• Qualification Verification
  • Theprincipalmustpossessproduction/operationqualificationsforexportgoods
  • TheagentmustholdvalidAuthorizationcertificate

III.Comparison of Tax Refund Differences Between Self-Export and Agency Export

By comparing the latest policies in 2025,the main differences in tax rebates between the two models are as follows:

• taxrefundentity:Self-exportallowstheexportingenterprisetodirectlyclaimtaxrefunds,whileagencyexportrequirestheprincipaltoclaimrefunds
• Riskbearing:Intheagencymodel,foreignexchangerisksarebornebytheprincipal
• DocumentTimeliness:Agencyexportmustcompletedocumenttransferwithin60daysaftergoodsdeparture

IV.Analysis of Typical Cases of Export Tax Rebate Agency in the 2025 Era

Case 1:A garment factory entrusted Agent A to export goods worth $500,000.Due to the agents 30-day delay in submitting the customs declaration copy,the principal missed the 90-day tax refund application period,resulting in a direct loss of ￥320,000 in tax refunds.

Case 2: Tech Company B successfully obtained a 13% tax refund rate by completing the following actions in advance through a formal agency channel for exporting integrated circuits:

• Includingclausesintheagencyagreementtoensureconsistencybetweencustomsdeclarationnamesandinvoices
• Requiringtheagenttosynchronizeforeignexchangeverificationprogressweekly
• Establishinganelectronicdocumenttrackingsystem

V.Three Core Recommendations for Choosing Agency Export Services

• Qualificationreview:Verifythecustomscreditratingoftheagencycompany(recommendedtochooseAEO-certifiedenterprises)
• ContractTerms:Mustspecifydocumenttransferdeadlinesandliabilityforbreachofcontractinwriting
• Processcontrol:Recommendmonthlyverificationofcustomsdeclarations,foreignexchangereceipts,andinvoiceinformation

It’s worth noting that the new measures implemented in 2025Intelligent customs declaration systemRequires all agency export documents to be electronically filed through the International Trade Single Window,with paper documents serving only as supplementary materials.Principals are advised to request real-time electronic document query access from agency companies to ensure transparency and timeliness of the tax refund process.