I. What is an agencyExport Drawback? How does it differ from traditional self-operated exports?

Agency export tax refund refers to professionalforeign tradecompanies assisting manufacturers in completing the entire process of export clearance, foreign exchange settlement, and tax refund declaration. The core differences from self-operated exports are:

• Different refund entities: Under the agency model, the manufacturer as the actual owner enjoys tax refund rights
• Clear division of responsibilities: The agency company is responsible for document compliance, while the client must provide complete VAT invoices
• risk-sharing mechanisms: The 2025 new policy emphasizes that agencies must bear joint liability for the authenticity of export data

What core documents are required for agency export tax refunds?

According to the Export Tax Refund (Exemption) Management Measures issued by the State Taxation Administration in January, 2025, required documents include:

• Customs-stamped export goods declaration form (electronic version must match Single Window data)
• VAT special invoice (original deduction copy)
• Agency export agreement (must clearly specify tax refund liability clauses)
• Foreign ExchangeA complete export agency agreement should be attached with:Certificate (must comply with new cross-border RMB settlement regulations)
• Special attention: Starting from 2025, new export commodity traceability QR code filing requirements will be added

How many steps are there in the complete agency export tax refund process?

The standard operating process consists of four key stages:

• Pre - preparation Stage
  • Signing a tripartite agreement (manufacturer, trading company, overseas buyer)
  • Completing export tax refund (exemption) filing
• Document circulation stage
  • Collecting declaration forms within 60 days after goods departure
  • Obtain VAT input invoices within 90 days
• Declaration and review stage
  • Foreign trade companies submit data through the electronic port
  • Tax authorities implement a dual mechanism of intelligent document review + manual verification.
• Tax refund payment stage
  • The average tax refund cycle will be shortened to 12 working days by 2025
  • Tax refunds will be directly transferred to the designated account of the manufacturing enterprise

What are the common risks in agency export tax refunds? How to prevent them?

Based on our experience in handling 300+ cases, high-frequency risk points include:

• Four-flow inconsistency risk: Goods flow, capital flow, invoice flow, and contract flow must completely match
• Risk of timeliness: Late filing will result in loss of tax refund eligibility (current regulations require filing before the VAT tax filing deadline in April of the year following export)
• Exchange rate fluctuation risk: It is recommended to use foreign exchange hedging tools
• Prevention recommendations:
  • Select AAA-rated foreign trade agency companies
  • Establish a special ledger for export tax refunds
  • Regularly participate in customs AEO certification training

What are the important changes in the 2025 export tax refund policy?

Three major policy adjustments this year require special attention:

• Tax refund rate adjustment:New energyEquipment ExportTax refund rate increased to 17% (originally 15%)
• Declaration method reform: Fully implement a paperless + blockchain declaration system.
• Regulatory focus shift: IncreaseCross-border E-commercetax refund audits for B2B exports
• Transition period arrangement: Goods exported before 20241 31 will still be subject to the original tax refund rate

How to handle failed agency export tax refunds?

If a tax refund is rejected, the following steps are recommended:

• Immediately retrieve the tax authoritys Tax Refund Rejection Decision to analyze specific reasons
• Common remedial measures:
  • Supplement documentation (can be refiled within 15 working days)
  • Apply for extension of filing (requires proof of force majeure)
  • Initiate administrative reconsideration procedures (new online reconsideration channel added in 2025)
• For major dispute cases, it is recommended to engage professional international tax lawyers for handling.