The three-tier progressive logic of the tax exemption policy for imported equipment

Under the framework of the latest revised "Industrial Structure Adjustment Guidance Catalog" in 2025, the import equipment tax exemption policy exhibits a tiered applicability characteristic:National Strategic Projects > Provincial Key Projects > Enterprise Technological Upgrades。Agency enterprises must accurately grasp the differences in policy levels:

• National-level projects are eligible for full-process tax exemption (including customs duties and value-added tax).
• Provincial key projects are only exempt from tariffs.
• The technological renovation project must meet the certification of equipment advancement (an ISO 17025 test report is required).

Five Key Control Points for Tax-Free Declaration

Announcement No. 38 of the General Administration of Customs in 2025 explicitly requires that agency enterprises must establishWhole Lifecycle Supervision System, with a focus on controlling the following key aspects:

• Verification of equipment technical parameters
  • Please refer to the "National Catalogue of Imported Technologies and Equipment Supported by the Government" (2025 Edition) for comparison.
  • The parameter deviation must not exceed ±5% of the value indicated in the catalog.
• Timeliness of Project Approval Documents
  • The validity period of the NDRC filing documents has been shortened to 12 months.
  • The environmental approval document must include a carbon emissions assessment section.
• Proof of capital flow
  • Foreign Exchange Administration's New Version of FDI Registration Certificate
  • Cross-border RMB payments require the provision of the central bank filing number.
• Equipment Usage Supervision
  • Submit the usage report within 60 days after installation and debugging.
  • Upload equipment operation data to the customs system every quarter.
• Follow-up verification mechanism
  • Establish dedicated equipment ledgers (retention period extended to 8 years).
  • Coordinate with customs for remote video inspection (5G-enabled device required).

Three Substantive Policy Changes in 2025

Compared to previous policies, this year's adjustments place special emphasis onTechnical controllabilityandIndustrial compatibility:

• Added the access requirement for "Intelligent Equipment Operation and Maintenance System".
  • Compatibility with domestic operating systems (Kylin/UOS) is required.
  • The data interface complies with the GB/T 38674-2025 standard.
• Strengthen the assessment of localized services
  • Require suppliers to establish a 4-hour response service center domestically.
  • The spare parts inventory reserve shall not be less than 15% of the total equipment value.
• Introduce a carbon footprint traceability mechanism.
  • The carbon emissions throughout the entire lifecycle of the equipment must not exceed the industry benchmark value.
  • The transportation process requires the use of?New Energy?The proportion of logistics tools is ≥30%.

Analysis of typical dispute cases

Case 1:A semiconductor company was required to pay an additional 23 million yuan in taxes due to the technical parameters of its imported lithography machine exceeding the standard (by 7%). The dispute centered on the company's claim that the catalog's listed values were technologically outdated. Ultimately, the court ruled to uphold the customs decision.

Case 2:?Medical Devices?The agency successfully invoked the "Public Health Emergency Equipment" clause to obtain full tax exemption, with the key evidence being the equipment's modular modification capability, allowing for rapid conversion to epidemic prevention purposes.

The Four-Dimensional Strategy for Risk Prevention and Control

• Establish a pre-classification dispute resolution mechanism (it is recommended to reserve 3% tariff deposit).
• Improve the technical document management system (blockchain-based notarization is recommended).
• Establish a policy early warning system (monitor monthly updates from the Tariff Policy Department of the Ministry of Finance).
• Develop a multidisciplinary customs team (requiring expertise in both electromechanical engineering and customs law).

Under the new regulatory environment in 2025, the tax exemption for imported equipment has evolved from a mere tax incentive to...Industrial Chain Compliance ManagementAn essential component. Agency enterprises must establish a comprehensive risk control system covering the entire process from project initiation and equipment selection to customs declaration and subsequent supervision, with particular emphasis on two critical risk points: verification of technical parameters and oversight of the usage process. It is recommended that enterprises conduct professional policy compliance audits before launching major projects to avoid significant economic losses due to misunderstandings of policies.