The Three-Tier Progressive Logic of Import Equipment Tax Exemption Policies

Under the framework of the newly revised Industrial Structure Adjustment Guidance Catalog in 2025, the import equipment tax exemption policy exhibits a tiered applicability feature:National strategic projects > Provincial key projects > Enterprise technological upgradesAgency companies must accurately grasp the differences in policy levels:

• National-level projects can enjoy full-process tax exemptions (tariff + VAT)
• Provincial key projects only exempt tariffs
• Technological upgrade projects must meet advanced equipment certification (requiring ISO 17025 test reports)

Five Key Control Points for Tax Exemption Declarations

Announcement No. 38 of the General Administration of Customs in 2025 clearly requires agency companies to establisha full-lifecycle supervision system, focusing on the following aspects:

• Verification of equipment technical parameters
  • Must refer to the National Supported Import Technology and Equipment Catalog 2025 edition
  • Parameter deviations must not exceed ±5% of the catalogs annotated values
• Timeliness of project approval documents
  • The validity period of NDRC filing documents has been shortened to 12 months
  • Environmental approval documents must include a carbon emission assessment section
• Proof of capital flow
  • New version of SAFE FDI registration certificate
  • Cross-border RMB payments require a central bank filing number
• Equipment Usage Supervision
  • Submit usage reports within 60 days after installation and debugging
  • Upload equipment operation data to the customs system quarterly
• Follow-up Verification Mechanism
  • Establish dedicated equipment ledgers (retention period extended to 8 years)
  • Cooperate with customs remote video inspections (requires 5G-connected equipment)

Three Substantive Policy Changes in 2025

Compared to previous policies, this years adjustments particularly emphasizetechnological controllabilityandIndustry compatibility:

• New Intelligent Equipment Operation and Maintenance System access requirements added
  • Must be compatible with domestic operating systems (Kylin/Tongxin)
  • Data interfaces compliant with GB/T 38674-2025 standard
• Strengthened localization service assessment
  • Suppliers required to establish 4-hour response service centers domestically
  • Spare parts inventory must not be less than 15% of total equipment value
• Introduction of carbon footprint traceability mechanism
  • Carbon emissions throughout equipment lifecycle must not exceed industry benchmark
  • Transportation process requiresNew energyLogistics tools proportion ≥30%

Analysis of typical dispute cases

Case 1:A semiconductor companys imported lithography machine incurred additional tax payment of 23 million yuan due to technical parameter exceedance (7% deviation). The dispute focused on the companys claim that catalog reference values were technologically outdated, but the court ultimately upheld the customs decision.

Case 2:Medical EquipmentAn agency successfully invoked the Public Health Emergency Equipment clause to obtain full tax exemption, with key evidence being the equipments modular transformation capability for rapid conversion to epidemic prevention use.

Four-dimensional risk prevention strategy

• Establish pre-classification dispute resolution mechanism (recommend reserving 3% tariff deposit)
• Improve technical document management system (recommend blockchain evidence storage)
• Build policy early warning system (monitor monthly updates from Ministry of Finance Tariff Department)
• Develop multidisciplinary customs team (requires both electromechanical engineering and customs law knowledge)

Under the new 2025 regulatory environment, imported equipment tax exemption has transformed from simple tax preference toIndustrial chain compliance managementan important component. Agency firms need to establish full-process risk control systems covering project initiation, equipment selection, customs declaration, and post-clearance supervision, with particular emphasis on technical parameter verification and usage process monitoring as key risk points. It is recommended that enterprises conduct professional policy compliance audits before major project launches to avoid significant economic losses due to policy misinterpretation.