I. Under the pure agency export model, who is the actual entity eligible for tax rebates?

According to the "Notice of the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Goods and Services" (2025 Revised Edition), in pure agency export businesses:

• The right to tax refund belongs to the entrusting party.: Manufacturing enterprises or trading companies holding VAT special invoices
• The agency only provides customs declaration services.: Does not participate in the ownership of goods and financial settlement.
• Three-flow consistency principle: Goods flow (agency export), fund flow (consignor)?Forex Settlement?）、 the flow of bills (client's input invoices) must be unified.

Agency?Tax Refund?What essential qualifications are required?

The latest regulations from the General Administration of Customs in 2025 require that the entrusting party must simultaneously meet the following conditions:

• Basic Qualifications:
  • Valid?Import/export?Enterprises need to have legal import and export qualifications, including:
  • Normally functioning electronic port system
  • The export tax refund (exemption) filing has been completed.
• Document requirements:
  • Notarized agency export agreement (must specify the ownership of tax refund rights)
  • The "Certificate of Agency Export Goods" issued by the agent
  • The proforma invoice must strictly correspond with the customs declaration information.

III. What are the changes in the export tax rebate declaration process for agents in 2025?

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

• Phase One: Document Preparation
  • Obtain the full set of customs clearance documents within 30 days after customs declaration.
  • After receiving the payment, generate the bank receipt voucher.
• Phase 2: System Operations
  • Submit the "?Foreign trade?"Enterprise Export Tax Rebate Declaration Details Form"
  • Upload electronically authenticated documents via blockchain.
• Stage 3: Tax Review
  • The average review cycle has been shortened to 12 working days (a 40% acceleration compared to 2023).
  • First-time applicants must undergo on-site verification.

IV. What are the common risks associated with export tax rebate agency services?

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

• Agency qualification risks:
  • Verify the AEO certification status of the customs agent.
  • Check for any records of administrative penalties
• Document management risk:
  • The commodity code on the customs declaration form must match the product name on the VAT invoice.
  • The difference in the amount of foreign exchange received must not exceed 5%.
• Risk of timeliness:
  • The declaration must be completed by the deadline for the VAT tax return filing in April of the following year after export.
  • Failure to declare within the prescribed time limit shall be deemed as domestic sales and subject to taxation.

V. How to Choose a Reliable Foreign Trade Agency Company?

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

• Qualification Review:
  • Verify the validity of the "International Freight Forwarding Enterprise Registration Form"
  • Verify the enterprise qualification on the SAFE (State Administration of Foreign Exchange) list.
• Service capabilities:
  • Do you provide a full-chain service including customs declaration, logistics, and tax refund?
  • Experience in customs clearance for special categories (such as hazardous materials, food, etc.)
• Risk Control System:
  • Whether to establish a dual-document review mechanism
  • Whether professional liability insurance has been purchased.