一、輸出稅還付What are the basic requirements?

According to the latest 2025 Measures for the Administration of Value-Added Tax and Consumption Tax on Exported Goods and Services, apply輸出稅還付All of the following conditions must be met simultaneously:

• Entity Qualification Requirements: The declaring entity must be an import and export enterprise registered and filed with customs.
• Principle of Documentary Correspondence：稅関申告書、付加価値稅請求書、外貨受領(lǐng)証は「三書類一致」が必要です。
• Time Limit: The export of goods must be declared before the April VAT filing period of the following year.

II. What is distinctive about the operating mechanism of agency-based exports?

Under the typical agency export model, the actual trade relationship exhibits a dual nature:

• Legal aspect: The agency company asConsignor on the customs declaration, assume primary responsibility for exports
• Business level: The commissioning party (the manufacturing enterprise) maintains actual controlTitle to the goodsとpricing power in transactions

this「名目上の輸出」と「実質(zhì)取引」の分離, directly leading to disputes over the ownership of tax refund rights. In the case of a Jiangsu textile company we served, when it exported goods worth $500,000 through an intermediary, both the customs declaration and the foreign-exchange recipient were the intermediary itself, forming a complete chain of evidence for the tax refund.

III. Why can’t the export agent apply for the tax rebate?

Based on a review of typical tax audit cases from the past three years, we have identified the key bottleneck preventing refunds:

• Break in the VAT chain: The invoice issued by the manufacturing company is made out to the agency, but the goods were not actually sold to the agency.
• Contradictory capital flows: Overseas payments are made directly to the agent's account, leaving the manufacturing company without direct transaction documentation.
• Regulatory Risk Prevention and Control：國家稅務(wù)総局は2024年に特に「偽裝自営?実質(zhì)代理」による脫稅行為の防止を強(qiáng)調(diào)しています。

4. How can export tax rebates be obtained legally and compliantly?

Drawing on two decades of hands-on experience, companies are advised to choose a path that aligns with their stage of development:

• Option 1: Apply for import and export operation rights
  • Minimum registered capital: RMB 500,000
  • Handle customs registration, China E-Port (e-Gateway) qualification, and other related certifications
• Option 2: Establish a genuine purchase-sale relationship
  • Sign a formal procurement contract with the agency
  • Ensure that funds are settled through the company’s official account and compliant invoices are issued.
• Option 3: Utilize a comprehensive foreign trade service platform
  • Choose a qualified integrated service provider for agency operations
  • 「オンライン化＋データ化」のモードを通じて、完全な証拠連鎖を保持する。

V. Common Misconceptions and Risk Warnings

Recently, we have identified three categories of high-risk operations that require special attention:

• Buy-out export: In 2025, customs has already uncovered 37 related cases, with the maximum penalty reaching 200% of the goods' value
• Invoice offset: Some companies attempt to use domestic sales invoices to offset export tax rebates, a practice that has now been explicitly defined as tax fraud.
• Account borrowing：第三者企業(yè)を利用して外貨を受け取ると、「三流不一致」が発生し、外貨管理局の検査を引き起こす可能性があります。