1.Is value-added tax (VAT) required for agency export service fees?

According to the current value-added tax policy in 2025,the agency export service fees belong toModern Services - Business Support ServicesCategories,to be classified by6% tax ratePay value-added tax.However,please note the following special circumstances:

• Iftheservicerecipientisanoverseasentityandtheconsumptionoccursentirelyoutsidethecountry,thecross-borderservicetaxexemptionpolicymayapply.
• Whenanagencyprovidesmixedservicessuchascustomsclearanceandlogistics,itmustaccountforeachbusinesstypeseparately.

2.Advance PaymentDo customs declaration fees and clearance fees need to be taxed?

The advance payment made by the agency companyReimbursement of actual expensesIncome that meets the following conditions may be excluded from taxable income:

• Pleaseprovidetheoriginalpaymentandreceiptvoucheroracopywiththeofficialsealaffixed.
• Clearlystipulatethecollectionandpaymentagencytermsinthecontract.
• Thefundflowcorrespondsone-to-onewiththebusinessdocuments.

Common risk points in practice:

• Failuretoaccountseparatelyresultinginbeingdeemedasanadditionalcharge.
• Advancefundsreceivedinterestundeclaredvalue-addedtax

III.How to handle tax treatment for installment payments?

In the agency export business,the tax refund sharing involves dual tax treatments:

• Regardingvalue-addedtax(VAT):ThetaxrefunditselfisnotsubjecttoVAT,buttheprofit-sharingagreementneedstobedistinguishedbynature.
  • Ifitisaserviceconsideration,value-addedtaxshallbecalculatedandpaidatarateof6%.
  • Ifitisaprofitdistribution,itdoesnotinvolvevalue-addedtax.
• Corporate income tax matters: Regardless of its nature,it shall be included in taxable income.

4.What tax issues are involved in cross-border payment service fees?

When paying agency service fees to overseas entities,special attention should be paid to:

• Withholdingandremitting6%VAT(Iftaxexemptionisnotapplicable)
• Withholdingandremitting10%CorporateIncomeTax(unlesstaxtreatybenefitsapply)
• Filingrequirements:TaxfilingisrequiredforsingletransactionsexceedingUSD50,000.

Special reminder: The new version of the Tax Treaty in 2025 has updated the criteria for identifying permanent establishments.It is recommended to conduct a tax treaty benefit analysis before making payments

V.How to Standardize Tax Management for Agency Export Business?

Recommended for enterprises to establishThree core mechanisms:

• ContractTermsReviewMechanism
  • Clarifythepricingmethodofservicefees
  • AgreementontheProvisionofInstruments
• Integration of "Business Flow,Capital Flow,and Document Flow" for Management Control
• Regular tax health check system (recommended quarterly)

Typical Case: A company incurred losses exceeding 2 million yuan due to overpayment of 13% value-added tax on goods by combining agency fees with goods value in invoicing.