I.Agency export,Do I need to file the VAT return on my own?

Under the 2025 Measures for the Administration of Value-Added Tax on Cross-Border Taxable Activities, agency exports are divided into two operational models:

• formal proxy: The entrusted party (the agency company) acts as the export entity, so the entrusting party does not need to file a separate declaration.
• Substantive agency: The principal retains its export entity status and is required to complete the full set of tax declarations on its own.

Key judgment criteriacustoms clearanceSingle "Domestic Consignor" field: If the agency company's name is displayed, formal agency applies; if the principal's name is displayed, it must be declared as self-operated export.

37. II. AgencyExport tax refundWhich party should file the declaration?

Pursuant to Article 18 of the “Administrative Measures for Value-Added Tax on Exported Goods and Services” revised by the Ministry of Finance in 2024:

• The entity eligible for tax refund isDomestic consignor on the export cargo customs declarationFor the record
• The agency company needs to provideTo declare tax refundsTo the Client
• The principal shall apply for the tax refund with supporting documents, special VAT invoices, and other relevant materials.

2025 New Requirement: The agency agreement must explicitly stateParty responsible for receiving foreign exchange, the State Administration of Foreign Exchange will verify the consistency between the remittance recipient and the customs declaration information.

III. How should accounting be handled for export on commission?

The standard operating procedure should include the following steps:

• Revenue recognition
  • Self-operated export: Revenue is recognized based on the FOB price.
  • Agency Export: Only the agency service fee revenue is recognized
• 15. Bill management
  • Must obtain an invoice issued by the agencyAgency Service Fee Invoice
  • RetainExport Goods Settlement StatementOriginal for reference

IV. How should cross-border tax-exempt service income be declared?

Key Points of the Continued Cross-Border Services VAT Exemption Policy for 2025:

• 39. Policy basis: Cai Shui [2016] No. 36, Appendix 4
• Declaration Requirements:
  • Enter it in line 16 of Appendix 1 to the VAT return form.
  • Need to prepareService ContractandForeign exchange receiptPending filing materials
• Common Misconceptions: Mistakenly classifying revenue from goods exported on behalf of others under the service-based VAT exemption category

V. How to Avoid Tax Risks in Agency Export?

2025 Key Customs Audit Focus – Notice from the General Administration of Customs:

• four-flow alignmentRisks
  • Mismatch between the goods flow (customs declaration) and the fund flow (foreign exchange receipt voucher) in terms of the principal.
  • Invoice flow (input invoices) contradicts contract flow (agency agreement)
• Preventive measures:
  • EstablishedDedicated Ledger for Agency Export Operations
  • Monthly reconciliationExport date, customs declaration amount, foreign exchange received amountThree elements
  • Reserve is complete.Email correspondence recordsandMeeting Minutes

VI. Common Declaration Error Cases in Agency Export

Case 1:In 2024, a certain enterprise declared export goods handled on an agency basis as if they were its own sales, resulting in:

• Repeated declaration of export revenue
• The refunded tax shall be recovered and a fine equal to 50% of the refunded amount shall be imposed.

Correct approach:Enter the amount of goods exported on an agency basis in the “Tax-exempt income” column of the VAT return, and attach a note clarifying the agency nature.

Case 2:The agency failed to issue it in a timely mannerTo declare tax refunds, resulting in:

• The client missed the 180-day tax refund filing deadline.
• The amount of refundable taxes lost exceeds RMB 2 million.

Response Plan:The certificate must be issued within 30 days from the date of customs declaration for the export of the goods.

VII. Key Changes to the 2025 Application Process

• Electronic Tax Bureau Upgrade: Added a dedicated declaration channel for agency export business
• Simplification of materials: Cancellation of the requirement for tax filing of agency agreements
• Enhanced supervision: Real-time data exchange and comparison between the State Administration of Foreign Exchange and the tax authorities

It is recommended that enterprises conduct quarterly reviews throughInternational Trade Single WindowVerify the consistency of the declared data and promptly correct any discrepancies.