Under the pure agency export model, who is the tax refund entity?

According to the Notice of the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Goods and Labor Services (2025 revised edition), in pure agency export business:

• Tax refund rights belong to the principal: Manufacturing enterprises or trading companies holding special VAT invoices
• The agency company only provides customs declaration services: Does not participate in goods ownership and fund settlement
• Three-stream consistency principle: Goods flow (agency export), fund flow (principal)A complete export agency agreement should be attached with:, document flow (principals input invoices) must be unified

AgencyExport DrawbackWhat essential qualifications are required?

According to the latest regulations of the General Administration of Customs in 2025, the principal must simultaneously meet:

• Basic Qualifications:
  • Validimport and exportEnterprises need to have legal import and export qualifications, including:
  • A normally functioning electronic port system
  • Completed export tax refund (exemption) filing
• Document requirements:
  • Notarized agency export agreement (must clearly specify tax refund rights)
  • Certificate of Agency Export Goods issued by the agency
  • Strict correspondence between proforma invoice and customs declaration information

What are the changes in the agency export tax refund declaration process in 2025?

In line with the upgrade requirements of the Golden Tax Phase IV system, the current declaration process is:

• Stage 1: Document preparation
  • Obtain complete customs declaration documents within 30 days after customs declaration
  • Generate bank foreign exchange receipt after receiving payment
• Stage 2: System operation
  • Submit Enterprise Export Tax Refund Declaration Details Form through the electronic tax bureauforeign tradeUpload electronically authenticated documents via blockchain
  • Average review cycle shortened to 12 working days (40% faster than 2023)
• Stage 3: Tax Review
  • First-time declarers must undergo on-site verification
  • What are the common risks in agency export tax refunds?

According to 2025 foreign trade dispute case analysis, special attention should be paid to:

According to the analysis of foreign trade dispute cases in 2025, special attention should be paid to:

• Agency company qualification risks:
  • Verify the AEO certification status of the customs agent
  • Check for any administrative penalty records
• Document management risk:
  • HS codes on customs declarations must match product names on VAT invoices
  • Foreign exchange receipt amount differences must not exceed 5%
• Risk of timeliness:
  • VAT tax returns must be completed before the deadline in April of the year following export
  • Untimely declarations will be treated as domestic sales for taxation

How to choose a reliable foreign trade agency company?

It is recommended to evaluate an agency company from three dimensions:

• Qualification Review:
  • Check the validity of the International Freight Forwarding Enterprise Filing Form
  • Confirm SAFE (State Administration of Foreign Exchange) listed enterprise qualification
• Service capabilities:
  • Whether comprehensive services including customs clearance, logistics, and tax rebates are provided
  • Special category clearance experience (e.g., hazardous materials, food products)
• Risk Control System:
  • Whether a dual-document review mechanism has been established
  • Availability of professional liability insurance