Can Tax Refunds Be Claimed Under Agency Export?

According toState Taxation Administration 2025 Latest Announcement, under the agency export modelthe actual supplier (entrusting party)is eligible for tax refund benefits. The agency company, as the entrusted party, must submit the Agency Export Goods Certificate to the tax authorities and assist the entrusting party in completing foreign exchange verification and VAT special invoices, among other tax refund requirements. It is worth noting that the agency company itselfcannot claim tax refunds, but it must fulfill legal obligations such as customs declaration record-keeping and document circulation.

What Conditions Affect AgencyExport DrawbackSuccess Rate?

To be implemented in 2025General Administration of Customs Order No. 38Explicitly requires that agency export tax refunds must simultaneously meet:

• Complete document chain
  • Agency agreement (must specify the responsible entity for tax refund)
  • VAT special invoice (product name and quantity must exactly match the customs declaration)
  • A complete export agency agreement should be attached with:Supporting documents (foreign exchange administration verification records)
• Qualification Verification
  • The principal must possess production/operation qualifications for export goods
  • The agent must hold validimport and exportAuthorization certificate

III. Comparison of Tax Refund Differences Between Self-Export and Agency Export

Comparing the latest 2025 policies, the tax refund differences between the two models are mainly reflected in:

• tax refund entity: Self-export allows the exporting enterprise to directly claim tax refunds, while agency export requires the principal to claim refunds
• Risk bearing: In the agency model, foreign exchange risks are borne by the principal
• Document Timeliness: Agency export must complete document transfer within 60 days after goods departure

IV. Analysis of Typical Agency Export Tax Refund Cases in 2025

Case 1:A garment factory entrusted Agent A to export goods worth $500,000. Due to the agents 30-day delay in submitting the customs declaration copy, the principal missed the 90-day tax refund application period, resulting in a direct loss of ￥320,000 in tax refunds.

Case 2:Tech Company B successfully obtained a 13% tax refund rate by completing the following actions in advance through a formal agency channel for exporting integrated circuits:

• Including clauses in the agency agreement to ensure consistency between customs declaration names and invoices
• Requiring the agent to synchronize foreign exchange verification progress weekly
• Establishing an electronic document tracking system

V. Three Core Recommendations for Choosing Agency Export Services

• Qualification review: Verify the customs credit rating of the agency company (recommended to choose AEO-certified enterprises)
• Contract terms: Must specify document transfer deadlines and liability for breach of contract in writing
• Process control: Recommend monthly verification of customs declarations, foreign exchange receipts, and invoice information

It is particularly important to note that the new 2025Intelligent customs declaration systemRequires all agency export documents to be electronically filed through the International Trade Single Window, with paper documents serving only as supplementary materials. Principals are advised to request real-time electronic document query access from agency companies to ensure transparency and timeliness of the tax refund process.