Can agency exports enjoy tax refund policies?

According to the 2025 Administrative Measures for Value-added Tax and Consumption Tax on Export Goods and Labor Services,the actual owner of goods in agency export models can still apply for tax refunds. The following conditions must be met:

• Goods must be actually declared for export andA complete export agency agreement should be attached with:
• The agency agreement clearly stipulates the ownership of tax refund rights
• manufacturing enterprises must complete tax exemption, deduction and refund filing (applicable to production-type exports)
• Obtain export goods certification documents provided by the agent

AgencyExport DrawbackWhat materials need to be prepared?

After the 2025 electronic port system upgrade, enterprises need to simultaneously submit the following documents:

• Basic documents
  • Agency export agreement with official seal (must clearly specify the tax refund subject)
  • Electronic signature versions of customs declaration forms and shipping documents
  • VAT special invoice (original deduction copy)
• Newly added materials (2025 new regulations)
  • Cross-border payment digital certificate authentication records
  • Blockchain logistics tracking credentials (Maritime Transportation/Air TransportationEDI data)
  • Foreign exchange administration verification receipt (automatically obtained through the single window system)

Will the agency company withhold my tax refund payment?

According to typical cases published by the General Administration of Customs in 2023,legitimate agency companies should not intercept clients tax refunds. The following safeguard measures are recommended:

• Select Class A enterprises holding ,foreign tradeForeign Trade Operator Filing Form,
• Specify tax refund arrival time limits in the agency agreement (usually within 15 working days after tax authority approval)
• Require the agent to provide real-time query access to tax refund progress
• Priority given to providers offeringTax refund advance payment servicesfrom agency companies (requiring 0.5-1% service fee)

What are the new changes in 2025 foreign exchange verification?

The foreign exchange monitoring system version 2.0 launched in March 2025 brings three major changes:

• Verification period shortened: Foreign exchange collection period adjusted from 9 months to 6 months after export (excluding bulk commodities)
• Automatic data matching: Agents must upload transaction codes within 72 hours after export
• Abnormal transaction alerts: Tax refunds exceeding USD 500,000 per transaction require submission of fund flow explanations

How to avoid agency export tax refund risks?

Based on our service experience with 200+ enterprises, we recommend focusing on:

• Four-stream consistency: Goods flow, capital flow, document flow and data flow must completely match
• Time efficiency management: Tax refund materials must be collected within 180 days after export (may be shortened to 150 days in 2025)
• Agency review:
  • Verify the agencys customs credit rating (must maintain general certification or above)
  • Confirm their electronic port operation permissions
  • Query records of no tax fraud penalties in the past three years

Note: The 2023 data cited in this article is sourced from the General Administration of Customs public report, while the 2025 policy basis comes from the interpretation document of Announcement No. 47 of the State Taxation Administration. Actual operations should comply with the requirements of the competent tax authorities.