Home»?Tax Refund?» After Using an Export Agent, Who is Ultimately Responsible for the Tax Rebate? Will the Agency Company Keep My Tax Rebate Funds?
?Export Agency?How is tax rebate responsibility divided in the model?
According to the 2025 latest edition of the?Tax Refund?Administrative Measures," the determination of eligibility for tax rebates follows thewhoever exports, whoever
290761 principle. In export agency business:
290762 The manufacturing enterprise (the entrusting party) holds the
290763 form, VAT special invoice, and other original vouchers
290764 The agency company (the entrusted party) is responsible for preparing customs declaration documents and foreign exchange collection and settlement
290765 The tax rebate application must be submitted by the
290766 actual business entity with export qualifications.
290767 Special Note: A case in Zhejiang in 2022 where an agency company was penalized for fraudulently obtaining tax rebates by using a client's qualifications shows that agency companies are not allowed to apply for tax rebates on their own.
290768 How to complete the entire tax rebate process through an export agent?
290769 The standard operating procedure includes three key stages:
290770 Sign an agency agreement with clear tax rebate clauses
290771 Confirm that the enterprise has completed the export tax rebate (exemption) filing
290772 The agency company provides copies of the customs pre-entry declaration form and shipping order
290773 The enterprise issues a VAT special invoice (with the agency company as the buyer)
290774 The enterprise submits the tax rebate application through the electronic tax bureau
290775 The tax authority verifies the information on the customs declaration form, invoice, and foreign exchange collection receipt
290776 The 2025 requirement from the State Taxation Administration for
290777 all five documents"?Forex Settlement?, Who gets the tax refund?Principles. In agency export business:
The manufacturing enterprise (the entrusting party) holds the?Customs Declaration?customs declaration form, VAT special invoice, and other original vouchers.
The agency company (the entrusted party) is responsible for preparing customs declaration documents and foreign exchange collection and settlement.
The tax rebate application must be submitted by theactual business entity with export qualifications.Complete
Special Note: A case in Zhejiang in 2022 where an agency company was penalized for fraudulently obtaining tax rebates by using a client's qualifications shows that agency companies are not allowed to apply for tax rebates on their own.
How to complete the entire tax rebate process through an export agent?
The standard operating procedure includes three key stages:
Pre - preparation Stage
Sign an agency agreement with clear tax rebate clauses.
Confirm that the enterprise has completed the export tax rebate (exemption) filing.
Document circulation stage
The agency company provides copies of the customs pre-entry declaration form and shipping order.
The enterprise issues a VAT special invoice (with the agency company as the buyer).
Declaration and review stage
The enterprise submits the tax rebate application through the electronic tax bureau.
The tax authority verifies the information on the customs declaration form, invoice, and foreign exchange collection receipt.
What core materials are needed for export tax rebate through an agent?
The 2025 requirement from the State Taxation Administration for theall five documents completestandard:
Export Goods Declaration Form with Customs Inspection Seal
Agency export agreement (the tax rebate liability clause needs to be clearly defined)
Foreign exchange collection voucher verified by the State Administration of Foreign Exchange
Proof of export of goods by agent (attachment to the commission agency agreement)
Copy of the Export Sales Contract
Special reminder: A case in Guangdong in 2024 where an enterprise's tax rebate was delayed due to missing shipping documents proves that the completeness of documents directly affects the timeliness of tax rebates.
How long does the tax rebate cycle for export agency take?
Time node control under normal circumstances:
Document collection period: Within 15 working days after the goods depart from the port
Tax authority review period: Within 20 working days after application (can be shortened to 5 days for Class I export enterprises)
Tax refund amount credited: Within 10 working days after approval
Note: A pilotsmart tax rebatesystem in the Yangtze River Delta region in 2025 allows a single tax rebate to be credited in as fast as 3 days.
What are the tax rebate risks in the export agency model?
Three types of risks that require key prevention:
Document Risk
The commodity code on the customs declaration form does not match the product name on the invoice
The difference between the foreign exchange receipt amount and the customs declaration amount exceeds 5%.
Time Sensitivity Risk
Exceeding the application deadline of April 30 of the year following the export date
Exchange rate conversion errors for cross-year business
Compliance risk
The agency company issues fraudulent VAT invoices
Exported goods involve controlled categories that were not declared
How to choose a reliable export tax rebate service provider?
It is recommended to evaluate from four dimensions:
Qualification review: Holds an international freight forwarding qualification certificate
System Capability: Has the capability for data integration with the electronic port
: Document review process, historical data of error rates: Has established a three-tier document review system
History records: No major tax violations in the past three years
The 2024 audit report of a listed company shows that choosing an AEO-certified agency company can reduce tax rebate risks by 37%.