How is tax rebate responsibility divided in the model?

According to the latest 2025 version of "Administrative Measures," the determination of eligibility for tax rebates follows thewhoever exports,whoever290761 principle.In export agency business:290762 The manufacturing enterprise (the entrusting party) holds the290763 form,VAT special invoice,and other original vouchers290764 The agency company (the entrusted party) is responsible for preparing customs declaration documents and foreign exchange collection and settlement290765 The tax rebate application must be submitted by the290766 actual business entity with export qualifications.290767 Special Note: A case in Zhejiang in 2022 where an agency company was penalized for fraudulently obtaining tax rebates by using a client’s qualifications shows that agency companies are not allowed to apply for tax rebates on their own.290768 How to complete the entire tax rebate process through an export agent?290769 The standard operating procedure includes three key stages:290770 Sign an agency agreement with clear tax rebate clauses290771 Confirm that the enterprise has completed the export tax rebate (exemption) filing290772 The agency company provides copies of the customs pre-entry declaration form and shipping order290773 The enterprise issues a VAT special invoice (with the agency company as the buyer)290774 The enterprise submits the tax rebate application through the electronic tax bureau290775 The tax authority verifies the information on the customs declaration form,invoice,and foreign exchange collection receipt290776 The 2025 requirement from the State Taxation Administration for290777 all five documents",Who gets the tax refund?Principles.In agency export business:

• Themanufacturingenterprise(theentrustingparty)holdsthecustomsdeclarationform,VATspecialinvoice,andotheroriginalvouchers.
• Theagencycompany(theentrustedparty)isresponsibleforpreparingcustomsdeclarationdocumentsandforeignexchangecollectionandsettlement.
• Thetaxrebateapplicationmustbesubmittedbytheactualbusinessentitywithexportqualifications.Complete

Special Note: A case in Zhejiang in 2022 where an agency company was penalized for fraudulently obtaining tax rebates by using a client’s qualifications shows that agency companies are not allowed to apply for tax rebates on their own.

How to complete the entire tax rebate process through an export agent?

The standard operating procedure includes three key stages:

• ThePreparationStage
  • Signanagencyagreementwithcleartaxrebateclauses.
  • Confirmthattheenterprisehascompletedtheexporttaxrebate(exemption)filing.
• Document circulation stage
  • Theagencycompanyprovidescopiesofthecustomspre-entrydeclarationformandshippingorder.
  • TheenterpriseissuesaVATspecialinvoice(withtheagencycompanyasthebuyer).
• Declaration and review stage
  • Theenterprisesubmitsthetaxrebateapplicationthroughtheelectronictaxbureau.
  • Thetaxauthorityverifiestheinformationonthecustomsdeclarationform,invoice,andforeignexchangecollectionreceipt.

What core materials are needed for export tax rebate through an agent?

In 2025,the State Taxation Administration requires that.all five documents completestandard:

• ExportGoodsDeclarationFormwithCustomsInspectionSeal
• Agencyexportagreement(thetaxrebateliabilityclauseneedstobeclearlydefined)
• ForeignexchangecollectionvoucherverifiedbytheStateAdministrationofForeignExchange
• Proofofexportofgoodsbyagent(attachmenttothecommissionagencyagreement)
• CopyoftheExportSalesContract

Special Note: The case of a Guangdong-based company in 2024,where the delay in tax refund was caused by the lack of shipping documents,proves that the completeness of these documents directly affects the timeliness of tax refund.

How long does the tax rebate cycle for export agency take?

Time node control under normal circumstances:

• Documentcollectionperiod:Within15workingdaysafterthegoodsdepartfromtheport
• Taxauthorityreviewperiod:Within20workingdaysafterapplication(canbeshortenedto5daysforClassIexportenterprises)
• Taxrefundamountcredited:Within10workingdaysafterapproval

Note: Pilot project in the Yangtze River Delta region in 2025smart tax rebatesystem in the Yangtze River Delta region in 2025 allows a single tax rebate to be credited in as fast as 3 days.

What are the tax rebate risks in the export agency model?

Three types of risks that require key prevention:

• DocumentRisk
  • Thecommoditycodeonthecustomsdeclarationformdoesnotmatchtheproductnameontheinvoice
  • Thedifferencebetweentheforeignexchangereceiptamountandthecustomsdeclarationamountexceeds5%.
• Time Sensitivity Risk
  • ExceedingtheapplicationdeadlineofApril30oftheyearfollowingtheexportdate
  • Exchangerateconversionerrorsforcross-yearbusiness
• Compliance risk
  • TheagencycompanyissuesfraudulentVATinvoices
  • Exportedgoodsinvolvecontrolledcategoriesthatwerenotdeclared

How to choose a reliable export tax rebate service provider?

It is recommended to evaluate from four dimensions:

• Qualificationreview:Holdsaninternationalfreightforwardingqualificationcertificate
• SystemCapability:Hasthecapabilityfordataintegrationwiththeelectronicport
• Riskcontrolsystem:Hasestablishedathree-tierdocumentreviewsystem
• Historyrecords:Nomajortaxviolationsinthepastthreeyears

The audit report of a listed company for 2024 shows that choosing an agency company with AEO certification can reduce the risk of tax refund by 37%.