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Who Should Bear the Responsibility for Export Tax Rebate Agency? What Key Risks Are Hidden in the Settlement Process?

Who Should Bear the Responsibility for Export Tax Rebate Agency? What Key Risks Are Hidden in the Settlement Process?

AgentlyExport tax refundWho should bear the responsibility?

According to the latest 2025 edition of the "Administrative Measures for Value-Added Tax and Consumption Tax on Export Goods and Labor Services," the tax refund rightsThe legally designated party is the exporting enterprise.。AtAgency export,Under this mode, both parties shall clearly agree in writing:

  • The client shall provide compliant special VAT invoices.
  • The agent completes the export customs declaration and foreign exchange collection procedures.
  • Tax Refund Benefit Allocation Ratio and Settlement Milestones

In practice, common disputes often arise from missing contract clauses, such as a garment export company failing to specifyExchange rate fluctuation compensation mechanism, resulting in a 3.2% exchange loss when the tax refund was received.

How to accurately calculate the tax refund settlement cycle?

According to data from the General Administration of Customs in 2025, the national average tax refund processing time has been reduced to23 working days, but agency export requires additional consideration of the following time factors:

  • Internal process of the agent (5-7 working days)
  • Document transmission time limit (reduced to 72 hours through electronic transmission)
  • Cross-border payment clearing cycle (3-5 business days for major currencies)

It is recommended to clarify in the contract"Settlement Terms of T+N", for example, stipulating "settlement shall be completed within T+3 business days from the date the tax refund is credited to the account."

What invoice issues may lead to a tax refund rejection?

Tax inspection cases in 2025 indicate that agencyExport tax refundThe three main causes of failure:

  • The discrepancy rate between the product names on VAT invoices and customs declarations accounts for 42%.
  • The foreign exchange verification discrepancy rate accounts for 31%.
  • The time logic contradiction rate in logistics documents accounts for 17%.

Proposal to establishThe "Three-Single Comparison" Mechanism: Complete cross-verification of the commercial invoice, packing list, and customs declaration form 72 hours prior to shipment.

How to Effectively Protect Your Rights When the Agent Delays Tax Refunds?

The following measures can be taken:"Four-Step Progressive" Solution Approach:

  • Step 1: Send a written demand letter (retain the EMS postal receipt)
  • Step 2: Apply to the customs for a duplicate of the export certificate.
  • Step 3: Report abnormal foreign exchange receipts to the State Administration of Foreign Exchange.
  • Step 4: Initiate commercial arbitration (it is recommended to designate the Beijing/Shanghai Arbitration Commission).

A machinery export company successfully recovered 870,000 yuan in withheld tax refunds from its agent through arbitration and was compensated for interest on the occupied funds.

How to Avoid Risks in Export Tax Rebate Through Agents?

Recommended adoptionThe "Trinity" Risk Control System:

  • Qualification review:
    • Check the agents customs AEO certification level
    • Check the registration status of the foreign exchange income and expenditure directory
  • Process monitoring:
    • Request real-time access to the read-only account of the customs declaration system.
    • Participation in the joint control of foreign exchange collection accounts
  • Settlement Guarantee:
    • Require the provision of a bank payment guarantee
    • Set up a joint custody account for tax refund funds

A listed company reduced its bad debt ratio for export agency from 1.7% to 0.3% through this system.

When will the export tax rebate be paid by the agent? Is it legal for the agency company to withhold the tax rebate funds?
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How to handle export tax rebate through an agent? What are the key considerations in the latest 2025 procedures?
Next ? June 30, 2025