Can the agency export model handle tax refunds independently?

According to the current policy in 2025, entities eligible for tax refunds must meet two core requirements:Qualification as a General VAT TaxpayerandOwnership of Export GoodsIn the context of export agency business:

• Production enterprises can independently apply for tax refunds by submitting agency agreements.
• Pure trading companies must achieve tax refunds through comprehensive service enterprises.
• When the agency company only provides logistics and customs clearance services, the principal retains the right to tax refund.

What key documents are required for self-processing of tax refunds?

In 2025, the General Administration of Customs will implement theElectronic Document Filing SystemRequest the enterprise to prepare:

• Basic documents:
  • Electronic record of customs declaration (must reflect the separation between the operating unit and the shipping unit)
  • VAT Special Invoice (the issuer must be the same as the manufacturer)
• Supporting evidence:
• Agency Export Agreement (clarifying ownership of goods and entitlement to tax refunds)
• Foreign Exchange?Forex Settlement?Voucher (must match the currency and amount on the customs declaration form)

What are the key deadlines to note for tax refund applications?

The implementation by the State Taxation Administration in 2025Hierarchical and classified managementFor products that require the addition of inhibitors or stabilizers, relevant instructions should be provided to ensure the stability of the chemical products during transportation and storage.

• First-time filing enterprises must complete the process before the tax filing deadline in April of the following year after export.
• Class I enterprises can enjoy the "review upon submission" policy (fastest fund arrival within 15 working days).
• Cross-border e-commerce goods subject to the 7210 regulatory code have their declaration period extended to 6 months.

What are the risk points of self-tax refund for export agency?

Audit cases from the past three years indicate that the primary risks are concentrated in:

• The goods flow does not match the document flow (especially in third-party payment scenarios).
• The issuance time of the VAT invoice is later than the customs declaration date.
• The agency company was included in the customs' list of discredited enterprises, resulting in joint liability.

How to choose the optimal tax refund method?

It is recommended that enterprises make decisions based on their operational scale:

• Enterprises with an annual export volume exceeding 20 million:
  • Self-built?Tax Refund?Team (cost accounts for approximately 0.8% of the total tax refund)
  • Configure the ERP system to achieve automated document management.
• Suggestions for small, medium, and micro enterprises:
• Please select an agency company with comprehensive foreign trade service qualifications.
• Adopt the "export by purchasing orders + 1039 market procurement" combined model.

Special Notice: New Additions by the General Administration of Customs in 2025Intelligent Document Review SystemEnterprises can check the tax refund progress in real time through the single window. It is recommended that enterprises operating for the first time apply to the competent tax authority in advance.Tax Refund Filing Pre-review Service, to avoid delays in the tax refund cycle due to documentation issues.