I. Who bears the tax liability for export under an agency arrangement in foreign trade?

According to the current Provisional Regulations on Value-Added Tax, export under foreign trade agency is conducted「誰(shuí)が経営するか、誰(shuí)が納稅する」Principles. In practice, pay attention to:

• The agency enterprise as通関リスト上の「経営単位」が、責(zé)任を負(fù)う輸出稅還付reporting obligation
• The commissioning party must provide genuine and valid input invoices to constitute the basis for tax refund.
• Joint and Several Liability in Special Circumstances:
  • The agent knowingly applied for tax refunds on behalf of the principal despite being aware that the invoices were fraudulently issued.
  • 両者は「稅込み契約」を締結(jié)し、納稅義務(wù)を回避した。

II. How is the VAT calculated and refunded for export under an agency arrangement?

2025年も輸出貨物?労務(wù)に対する増値稅「免稅?相殺?還付」政策が継続して実施され、具體的な手順は以下の通りです：

• Exempt:Exemption from value-added tax at the export stage
• Arrive:Input VAT can be credited against domestic sales tax payable
• Withdraw:Any unused input VAT shall be refunded.

Sample calculation: For a batch of exported goods, the input VAT is 100,000 yuan, and the domestic sales tax payable is 60,000 yuan; therefore, the actual refund amount = 100,000 yuan – 60,000 yuan = 40,000 yuan

III. What application materials need to be prepared for export by proxy?

For the 2025 e-Tax Bureau filing, the following scanned documents must be uploaded simultaneously:

• Agency Export Agreement (tax liabilities must be explicitly stipulated)
• Original customs declaration and packing list
• Value-Added Tax (VAT) Special Invoice (Deduction Copy)
• Foreign exchange receipt voucher (receipt ratio not less than 85%)
• Certificate of Agency for Export Goods issued by the principal

四、クロスボーダー決済What taxes and fees are involved in the service charge?

Note on overseas service fees collected by foreign trade agents:

• Value-added Tax: Cross-border taxable services are subject to a zero tax rate
• Income Tax:
  • If the agency enterprise has no establishment abroad, determination shall be based on the place where the service is performed.
  • Income attributable to a permanent establishment must be declared and taxed in the source country

V. How should the refunded tax be handled after the goods are returned?

Under the latest 2025 regulations, the return of exported goods must be handled on a case-by-case basis:

• Unclaimed Tax Refund: Directly amend the export declaration data
• Tax refund received less than 3 years ago: repay the refunded tax plus late-payment interest
• Special Handling Situations:
  • Returns due to quality issues may be exempt from supplementary tax.
  • Re-exported goods after repair can be re-declared

VI. How to Guard Against Tax Risks in Export Agency Arrangements?

It is recommended that enterprises establish a three-tier risk control mechanism:

• Contract Review:Clearly stipulate provisions such as invoice provision and tax liability.
• Document Management:Establish a corresponding relationship chain among the customs declaration, invoice, and transport documents.
• Fund Monitoring:Ensure that the remittance and receipt routes are consistent with the contracting party.

VII. 2025輸出稅還付What are the new changes in the policy?

Key policy adjustments to watch this year include:

• The tax refund review period is shortened to within 10 working days (for Category I enterprises)
• New tax-refund green channel for cross-border e-commerce B2B direct export (Model 9710)
• 「買い手払い輸出」などの違規(guī)行為を厳しく取り締まり、ブラックリストの共有メカニズムを構(gòu)築する