I.Does the service fee need to pay value-added tax?

According to the latest "Regulations on the Application of Zero-rated and Tax-free VAT Policies to Cross-border Taxable Activities" issued in 2025,export agency services that meet the following conditions can enjoy tax exemptions.the value - added tax exemption policy:

• TheagentholdsalegitimateEnterprisesneedtohavelegalimportandexportqualifications,including:
• Theservicecontentisdirectlyrelatedtothewholeprocessofgoodsexport(customsdeclaration,transportation,Damageduringtransportation
• Theagencycontractisconsistentwiththebillinformation

It should be noted that if the agent also providesdomestic transportation,warehousing and other supporting servicesthe income from this part needs to pay value - added tax at a rate of 6%.

How does corporate income tax handle the income from agency services?

The corporate income tax treatment of agency service fees needs to distinguishthe different positions of the principal and the agentPrincipal

• Thefeespaidtoacompliantagencycompanycanberegardedas:
  • salesexpensesdeductedbeforetaxItisnecessarytoobtainaVATordinaryinvoiceortax-exemptinvoice
  • Agent
• The cost and expenses corresponding to tax - exempt income:
  • shallnotbedeductedinputtaxItisnecessarytoseparatelyaccountfortax-exemptitemsandtaxableitems
  • AccordingtoAnnouncementNo.45oftheMinistryofFinancein2025,forcross-borderagencyservicefees,attentionshouldbepaidto:

What additional taxes and fees are involved in cross - border payment of agency fees?

According to the Ministry of Finance’s Announcement No.45 of 2025,cross-border agency service fees need to be paid attention to:

• Overseasagenciesneedtowithholdvalue-addedtaxat6%:
  • Theenterpriseincometaxappliesawithholdingincometaxrateof10%(canbereducedorexemptedifthereisataxtreaty)
  • Additionaltaxesandfees
• Urban maintenance and construction tax (7% of the value - added tax amount):
  • Educationsurcharge(3%ofthevalue-addedtaxamount)
  • Localeducationsurcharge(2%ofthevalue-addedtaxamount)
  • Case1:Impropersplittingofmixedservices

Analysis of common tax risk cases

An agency company combined the customs declaration service (tax - exempt) and domestic transportation service (taxable) for invoicing,resulting in underpayment of value - added tax of 180,000 yuan.Eventually,the tax was recovered and a fine of 0.5 times was imposed.

Case 2: Lack of cross - border payment vouchers

When an enterprise pays overseas agency fees,it fails to retain

service contracts,payment vouchers,pro forma invoicesand other materials as required,and the tax authority adjusted the taxable income by increasing it by 1.2 million yuan.System for separate accounting of agency services

5.Suggestions for Tax Compliance Operations in 2025

• EstablishWhenmakingcross-borderpayments,itisrequiredtoprovidesystem
• Requiredforcross-borderpaymentsCertificateofTaxResidency
• ConductregularlyTransferpricingDocumentpreparation
• UtilizefreetradezonesImmediaterefundofvalue-addedtaxPreferentialpolicies