I. Under the agency export model, who exactly is the statutory taxpayer?

In accordance with the "Provisional Regulations on Value-Added Tax of the People's Republic of China" and the latest revised "Value-Added Tax Management Measures for Export Goods and Services" in 2025,The agency export business is subject to dual taxation obligation recognition criteria.:

• Formal Requirement: The "Domestic Consignor" field on the customs declaration form records the exporting enterprise.
• Substantive requirements: actualA complete export agency agreement should be attached with:The principal and the contracting party of the purchase and sales agreement

The 2025 tax inspection typical cases revealed that a certain...foreign tradeThe agency is recognized as the primary taxpayer for simultaneously meeting the following conditions:① Control over goods pricing ② Direct collection of foreign exchange payments ③ Issue VAT special invoices to the factoryThis indicates that the traditional "pure agency" model is being challenged by the substantive operation recognition criteria.

II.Export DrawbackHow is the reporting entity determined?

The ownership of tax refund rights for export agency remainsThree major judgment principles:

• The principle of consistency between the declaration form and the VAT invoice header
  • Sometime in 2025Cross-border E-commerceThe company lost 3.2 million yuan in tax rebates due to inconsistency between the customs declaration form and the invoice header.
• The principle of traceability in foreign exchange payment and receipt paths.
• Completeness of Business Authenticity Supporting Documents
  • Please provide the three-chain consolidated evidence, including the agency agreement, fund flow records, and logistics documents.

III. How to Complete VAT Declaration for Agency Export?

According to Announcement No. 18 of the State Taxation Administration in 2025, the handling of value-added tax for export agency presents...New changes:

• Manufacturing enterprise entrusts an agent for export:
  • Continue to apply the "exemption, credit, and refund" tax policy.
  • New Electronic Power of Attorney Filing System (to be launched in January 2025)
• Foreign trade enterprises entrust agents for export:
  • It is mandatory to simultaneously upload the purchase and sales contract through the "Single Window."
  • The deadline for foreign exchange receipt is shortened to 180 days after the export of goods.

IV. What are the common obstacles in export tax rebate agency?

Survey data from foreign trade enterprises in 2025 shows that,Three Main Reasons for Failed Export Tax Rebate Agency:

• Document chain breakage (accounting for 37%):
  • The agency agreement does not specify the subject of tax refund.
  • The logistics documents do not match the fund flow.
• The declaration time limit has expired (accounting for 29%).
• Agent qualification deficiencies (accounting for 18%):
  • Enterprises below Class B in customs are not allowed to handle tax refunds on behalf of others.
  • The impact of foreign exchange management classification levelsFX Settlement AgencySpeed

5. How to Establish a Compliant Tax Structure for Agency Export?

It is recommended that enterprises adoptTrinity risk prevention and control mechanism:

• Clarify the terms for resolving quality disputes
  • Clearly define the boundaries between "formal customs declaration" and "substantive operations."
  • Establish foreign exchange repatriation safeguard clauses
• Document Management:
  • Establish an "integrated four flows" electronic record system (contract flow, goods flow, capital flow, and invoice flow).
• Process monitoring:
  • Please verify the customs declaration data against the tax refund application progress on a monthly basis.
  • Regularly review the customs credit rating of the agent.

It is particularly important to note that, starting from 2025, the implementation of"Cross-Border Trade Facilitation Regulations"It is required that export agency services must retain complete electronic trail records. Companies are advised to prioritize agency service providers with AEO certification and adopt blockchain notarization technology to solidify transaction evidence.