EntrustAgency export,Is it eligible for tax exemption?

According to the latest 2025 "Notice of the Ministry of Finance and the State Taxation Administration on Value-Added Tax and Consumption Tax Policies for Export Goods and Labor Services," eligible entrusted agency export businesses can enjoy the VAT exemption policy. However, the following conditions must be met simultaneously:

• The agent has export operation rights and has completed the customs filing.
• The actual ownership of the exported goods belongs to the entrusting party.
• customs clearanceThe "Domestic Consignor" column indicates the name of the entrusting party.
• The recipient of the foreign exchange must be consistent with the entrusting party.

Differences in Taxation Between Self-Operated Exports and Agency Exports

There is an essential difference in the tax treatment between the two models:

• Self - managed exportApplicable to the "Exemption, Credit, and Refund" policy:
  • Exemption from value-added tax on export transactions
  • Deductible input VAT
  • Refund of the uncredited input VAT
• Agency export,Applicable tax exemption policy:
  • Only exempt from value-added tax (VAT) on the export stage.
  • The corresponding input tax shall not be deductible.

Key Points for Tax-Free Operations in Agency Exports for 2025

• A tripartite agreement must be signed (between the client, the agent, and the overseas buyer).
• The customs declaration form must include information of both the consignor and the agent.
• The foreign exchange receipt voucher must be settled through the client's foreign exchange account.
• The export invoice must be annotated with the phrase "agency export."

Common Operational Missteps Warning

• Misconception 1:Direct foreign exchange collection by the agent is tax-exempt.

  In 2023, a certain apparel company was required to pay back taxes of 870,000 yuan due to receiving foreign exchange through an agent. The correct approach should have been to receive the foreign exchange through the principal's account.

• Misconception 2:All agency models are tax-exempt.

  Buyout agency is subject to domestic sales taxation, and a machinery manufacturer was fined 350,000 yuan in 2024 for this reason.

Suggestions for Handling Special Circumstances

• Cross-border e-commerce retail exports: must be declared through the supervision method of the comprehensive pilot zone.
• Market procurement trade: Must use the 1039 customs supervision code.
• Foreign Trade Comprehensive Service Platform: Must obtain the qualification of "Comprehensive Foreign Trade Service Enterprise".

New Regulations on Tax Exemption Certificate Management for 2025

In accordance with Announcement No. 12 of 2025 issued by the State Taxation Administration, the following supporting documents for entrusted export agency must be retained for at least 10 years:

• Notarized original of the power of attorney
• Bank Payment and Receipt Voucher
• Copy of the cargo transport document
• Copy of Customs Release Notice

Authoritative Answers to Frequently Asked Questions

• Q:Can tax refunds be applied for in the case of export agency?
  A：The agency service has been canceled since 2012.Export tax refund, only self-operated exports by manufacturing enterprises are eligible for tax refunds.
• Q:What is the deadline for tax-free declaration?
  A：The goods are declared for export during the value-added tax filing period in April of the following year.

This document is prepared based on the currently effective regulations as of 2025. For specific business operations, please refer to the interpretation of the competent tax authority. It is recommended to engage a professional foreign trade agency service, which can reduce tax compliance risks by over 95%.