Can the agency export model handle tax refunds independently?

According to the current policy in 2025,the tax rebate subject needs to meet two core conditions:Qualification as a General VAT TaxpayerandOwnership of Export GoodsIn the context of export agency business:

• Productionenterprisescanindependentlyapplyfortaxrefundsbysubmittingagencyagreements.
• Puretradingcompaniesmustachievetaxrefundsthroughcomprehensiveserviceenterprises.
• Whentheagencycompanyonlyprovideslogisticsandcustomsclearanceservices,theprincipalretainstherighttotaxrefund.

What key documents are required for self-processing of tax refunds?

In 2025,the General Administration of Customs implemented the following measures:Electronic Document Filing SystemRequest the enterprise to prepare:

• Basicdocuments:
  • Electronicrecordofcustomsdeclaration(mustreflecttheseparationbetweentheoperatingunitandtheshippingunit)
  • VATSpecialInvoice(theissuermustbethesameasthemanufacturer)
• Supporting evidence:
• Agency Export Agreement (clarifying ownership of goods and entitlement to tax refunds)
• Foreign ExchangeVoucher (must match the currency and amount on the customs declaration form)

What are the key deadlines to note for tax refund applications?

In 2025,the State Taxation Administration will implement the following measures:Hierarchical and classified managementFor products that require the addition of inhibitors or stabilizers,relevant instructions should be provided to ensure the stability of the chemical products during transportation and storage.

• First-timefilingenterprisesmustcompletetheprocessbeforethetaxfilingdeadlineinAprilofthefollowingyearafterexport.
• ClassIenterprisescanenjoythe"reviewuponsubmission"policy(fastestfundarrivalwithin15workingdays).
• Cross-bordere-commercegoodssubjecttothe7210regulatorycodehavetheirdeclarationperiodextendedto6months.

What are the risk points of self-tax refund for export agency?

Audit cases from the past three years indicate that the primary risks are concentrated in:

• Thegoodsflowdoesnotmatchthedocumentflow(especiallyinthird-partypaymentscenarios).
• TheissuancetimeoftheVATinvoiceislaterthanthecustomsdeclarationdate.
• Theagencycompanywasincludedinthecustoms’listofdiscreditedenterprises,resultinginjointliability.

How to choose the optimal tax refund method?

It is recommended that enterprises make decisions based on their operational scale:

• Enterpriseswithanannualexportvolumeexceeding20million:
  • Self-builtTeam(costaccountsforapproximately0.8%ofthetotaltaxrefund)
  • ConfiguretheERPsystemtoachieveautomateddocumentmanagement.
• Suggestions for small,medium,and micro enterprises:
• Please select an agency company with comprehensive foreign trade service qualifications.
• Adopt the "export by purchasing orders + 1039 market procurement" combined model.

Special Note: In 2025,the General Administration of Customs added new items to the Catalogue of Prohibited and Restricted Items for Import and Export.Intelligent Document Review SystemEnterprises can check the tax refund progress in real time through the single window.It is recommended that enterprises operating for the first time apply to the competent tax authority in advance.Tax Refund Filing Pre-review Service,to avoid delays in the tax refund cycle due to documentation issues.