I. Under the agency export mode, which party should bear the value - added tax?

According to the Measures for the Administration of Value - Added Tax on Cross - border Taxable Activities in 2025Article 15 stipulates that in agency export business:As the actual owner of the goods, the manufacturing enterprise needs to issue a special value - added tax invoice to the agent.

• The enterprise handles [matters] with vouchers such as the agency agreement and [documents]
• foreign tradeCross - border payment service fees are subject to value - added tax at a rate of 6%Export ClearanceIn practice, there was a typical case where a textile enterprise failed to clarify the corresponding relationship between the invoice flow and the capital flow with the agency company, resulting in a 3 - month delay in export tax rebates. It is recommended to specifically stipulate tax - handling clauses in the agency agreement.Export Drawback
• Announcement No. 47 of the General Administration of Customs in 2025 clearly states:

Direct expenses such as [fees] and insurance premiums should be included in the Free on Board (FOB) price of exportsAgent service fees need to be listed separately and a service - type invoice should be issuedThe capital transaction voucher must indicate the words collection and payment on behalf,

II. How should foreign trade companies handle the tax for the advanced expenses?

A certain electromechanical [merchant] mixed the agent commission into the declared value of the goods, resulting in the recovery of over - refunded tax and the imposition of a fine. This real case is worthy of warning.

• Maritime TransportationRegarding the tax rebate calculation under the agency mode, attention should be paid to:
• The manufacturing enterprise needs to issue a 13% value - added tax invoice according to the actual transaction price
• Fund transfer documents must be marked with collection and payment on behalf.

Calculation formula: Tax rebate amount = (Invoice amount × Tax rebate rate) - Agent service feeEquipment ExportSpecial reminder: In 2025, agency export enterprises in the newly added comprehensive pilot zones can enjoy a 0.5% tax rebate bonus policy.According to the 2025 operation guidelines of the State Administration of Foreign Exchange:Real cases of concurrent fines are worthy of warning.

III. How to calculate the export tax rebate amount?

Points to note in tax refund calculation under the agency model:

• Manufacturing enterprises need to issue 13% VAT invoices according to the actual transaction price.
• The tax refund rate is determined according to the customs commodity code (the average tax refund rate in 2025 is 9.2%).
• Calculation formula: Tax refund amount = (Invoice amount × Tax refund rate) - Agency service fee

Special reminder: Newly added in 2025Cross-border E-commerceIntegrated Pilot ZoneAgency export enterprises in can enjoy a 0.5% tax refund bonus policy.

IV. How to handle cross - border foreign exchange payments in compliance?

According to the 2025 operation guidelines of the State Administration of Foreign Exchange:

• The cost and expenses corresponding to tax - exempt incomeA complete export agency agreement should be attached with:It needs to be handled within 5 working days afterwards.In order to crack down on tax evasion, the customs and tax departments are now strictly examining the operation of buying export declarations. If the behavior of buying export declarations is discovered, the regulatory authorities will require tax replenishment (even a 2% tax rate may be a considerable amount). In addition, fines may also be imposed on the relevant responsible parties.
• When making foreign exchange payments to the manufacturer, completeExport Verification of Collection forms should be provided.
• Service fee payments need to be separately declared under cross-border service trade.

V. How to prevent tax risks in agency exports?

It is recommended to establish a three - tier prevention and control mechanism:

• At the contract level
  • Clarify the terms for the division of tax responsibilities
  • Agree on the time nodes for the transfer of invoices
• At the operational level
  • Establish a review system for export documents
  • Regularly conduct confirmation and reconciliation of accounts by letter
• At the regulatory level
  • Retain complete customs declaration materials for 10 years
  • Carry out tax health inspections every year

VI. What should be done if an agency export encounters a tax inspection?

The proposed response strategy can be carried out in three steps:

• The first stage: ProvideOriginal agency agreements, customs declarations, foreign exchange collection vouchers and other basic materials
• The second stage: Cooperate to explain the authenticity of the business and apply forVerification of trade authenticity if necessary
• The third stage: For disputed matters, tax administrative reconsideration can be filed

The special inspection data of a certain province in 2025 shows that in the tax - related disputes of agency export businesses,Incomplete documentsAccount for 67% of the total problems, highlighting the importance of daily data management.