I.Export tax refundIs the right a revocable right?

In accordance with Article 51 of the Law of the People's Republic of China on the Administration of Tax Collection,Export tax refundIt is a statutory right granted by the state to export enterprises. However,Termination of the agency tax refund relationshipwithTermination of the right to tax refundThere is an essential difference:

• Tax refund eligibility is automatically invalidated due to changes in enterprise qualifications (e.g., loss of export operation rights).
• The termination of the agency agreement only terminates the principal-agent relationship and does not affect the enterprise's right to tax refund.
• The newly implemented "Electronic Management Regulations for Export Tax Refunds" in 2025 explicitly require that the entity applying for tax refunds must match the actual exporting entity.

II. Statutory Circumstances Allowing Termination of Agency Tax Refund

As confirmed by the National Taxation Service's 12366 hotline, the following circumstances qualify for applying to change the tax refund entity:

• The agency contract has expired without renewal.
  • The filing must be submitted to the competent tax authority 30 days in advance.
  • Provide proof of termination of the original agency agreement
• The enterprise obtains independent export qualification.
  • Complete the registration of the consignor and consignee for customs import and export.
  • Obtain the Electronic Port IC Card
• The agent has a record of major violations.
  • Please provide the tax authority's penalty decision notice.
  • Approved by the tax bureau at or above the municipal level.

III. Specific Operational Procedures for Terminating Agency Tax Refunds

According to the requirements of the latest 2025 edition of the "Administrative Measures for Export Tax Refund (Exemption)":

• Step 1: Issue a written termination notice to the original agent.
• Step 2: Submit the "Export tax rebate agent"Relationship Termination Application Form"
• Step 3: Process the modification of export tax rebate filing information.
  • Please provide new proof of tax refund account.
  • Please upload the video for legal representative identity verification.
• Step 4: Complete the ownership division of historical customs declarations.
  • Starting from 2025, the "one declaration, one main" system for customs declarations will be implemented.
  • The maximum segmentation period shall not exceed 45 working days.

IV. Three Major Risk Warnings for Mid-Term Termination of Agency

Based on the analysis of tax inspection case data from the past three years:

• Risk of input tax being stranded

  The new regulation in 2025 requires that the agent must complete the settlement of input tax credits within 60 days after contract termination. A late fee of 0.05% per day will be charged for overdue payments.

• Tax refund time limit pressure

  Self-declaring enterprises must complete document filing within 180 days after the goods are exported, which is 60 days shorter than the agency model.

• Breach of Agency Contract Compensation

  Industry practice generally stipulates that early termination requires payment of a penalty fee equivalent to 30%-50% of the remaining service period.

V. Professional Advice: Under What Circumstances Should Termination of Agency Be Avoided?

• Export products involving anti-dumping tariff items (requires professional declaration team)
• The average monthly export declaration volume of the enterprise is less than 20 (high self-management costs).
• There is an unrefunded amount exceeding 500,000 yuan spanning fiscal years (complex liquidation process).
• Special trade methods (such as Market Procurement Trade Model 1039)

VI. Special Notice on New Policy Changes for 2025

The Announcement No. 9 issued by the State Taxation Administration in January 2025 clearly states:

• Cancel the filing of paper agency agreements and fully implement electronic agreement verification and signing.
• Establish a "blacklist and whitelist" system for tax refund agents, with non-compliant agents to be publicly disclosed across the entire network.
• Enable the intelligent tax refund review system, and a declaration error rate exceeding 5% will trigger manual review.